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Since its first edition in 2010, the OECD Development Centre's Perspectives on Global Development report has tracked development trends and policy priorities in developing countries. This new report examines the phenomenon of discontent. Between the global financial crisis and the COVID-19 pandemic, discontent surged around the world. It was especially evident in middle-income countries and was often most acute amongst the middle classes that have emerged in developing countries over recent decades. The report explores the economic, political and sociological drivers of discontent and argues that building back better from the COVID-19 pandemic in developing countries will require approaches that simultaneously improve citizens' well-being, promote productive transformation and strengthen social cohesion. The report concludes by examining the international dimension of discontent and demonstrates how weaknesses and imbalances in the present multilateral system are eroding humankind's capacity for collective action in the face of global threats, notably the climate crisis. The rise in discontent has exposed failings in prevailing economic, social and political models at all levels: addressing discontent means fixing these systems, and doing so in an inclusive and sustainable manner.

As part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy agreed by the OECD/G20 Inclusive Framework on BEPS in October 2021, Amount B provides for a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.

This Policy Guidance is a product of the Development Assistance Committee’s multi-year programme of work on Illicit Financial Flows (IFFs) in oil commodity trading. It proposes a set of relevant, feasible actions for providers of official development assistance (ODA) to respond to IFFs in oil commodity trading. The aim is to enhance the mobilisation of domestic resources for the benefit of populations living in oil-producing developing countries, and enable integrity in their energy transition, particularly in carbon trade.

This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.

This report includes proposed changes to the OECD Model Tax Convention to prevent treaty abuse. Countries participating in the BEPS Project have agreed on a minimum standard to prevent treaty shopping and other strategies aimed at obtaining inappropriately the benefit of certain provisions of tax treaties. The report also ensures that tax treaties do not inadvertently prevent the application of legitimate domestic anti-abuse rules. The report clarifies that tax treaties are not intended to be used to generate double non-taxation and identifies the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country. The model provisions included in the report provide intermediary guidance as additional work is needed, in particular in relation to the limitation on benefits rule.

This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement.  It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.

Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping. It includes the aggregate results of the review and data on tax treaties concluded by the members of the OECD/G20 Inclusive Framework on BEPS as of 31 May 2022, as well as jurisdictional sections which contain detailed information for each member jurisdiction.

Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fourth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping. It includes the aggregate results of the review and data on tax treaties concluded by each of the 139 members of the OECD/G20 Inclusive Framework on BEPS on 31 May 2021, and also contains the jurisdictional section for each member. This is the first peer review process governed by a revised peer review methodology.

Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the sixth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping. It includes the aggregate results of the review and data on tax treaties concluded by the members of the OECD/G20 Inclusive Framework on BEPS as of 31 May 2023, as well as jurisdictional sections which contain detailed information for each member jurisdiction.

The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the third peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework. It includes the aggregate results of the review and data on tax treaties concluded by each of the 137 members of the Inclusive Framework on 30 June 2020 and it contains the jurisdictional section for each member. The data compiled for this peer review demonstrate that the MLI has been the tool used by the vast majority of jurisdictions that have begun to implement the minimum standard and that the MLI has started to impact tax treaties of jurisdictions that have ratified it.

The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the second peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework. It includes the aggregate results of the review and data on tax treaties concluded by each of the 129 members of the Inclusive Framework on 30 June 2019 and it contains the jurisdictional section for each member (see Annex 2). The data compiled for this peer review demonstrate that the MLI has been the tool used by the vast majority of jurisdictions that have begun to implement the minimum standard and that the MLI’s impact is expected to increase quickly as jurisdictions ratify it.

Accelerating the transition to net zero greenhouse gas (GHG) emissions is urgently required to contain the risks of climate change. As countries seek to reduce GHG emissions, they can employ or reform a wide range of policy instruments. This report tracks how explicit carbon prices, energy taxes and subsidies have evolved between 2018 and 2021. This is an important subset of the policy instruments available to governments. All instruments considered in this report either directly change the cost of emitting GHG or change electricity prices. Reforming these instruments could help to meet climate targets, lead to cleaner air and water, and improve public finances. The report covers 71 countries, which together account for approximately 80% of global GHG emissions and energy use. Explicit carbon prices, as well as energy taxes and subsidies are detailed by country, sector, product and instrument. The use of a common methodology ensures comparability across countries. Summary indicators facilitate cross-country comparisons and allow policy makers and the public to keep track of progress made and identify opportunities for reform.

La lucha contra la erosión de bases y el traslado de beneficios se ha convertido en una prioridad para gobiernos de todo el mundo. Los países de la OCDE y del G20, trabajando juntos en igualdad de condiciones, adoptaron en 2013 un Plan de Acción de 15 puntos para abordar BEPS. Más allá de garantizar la recaudación alineando la potestad tributaria con la actividad económica y la creación de valor, el Proyecto OCDE/G20 BEPS busca producir un paquete consensuado de normas de fiscalidad internacional capaces de abordar BEPS y de proteger las bases imponibles, ofreciendo al mismo tiempo previsibilidad y seguridad jurídica a los contribuyentes. Uno de los objetivos claves del proyecto es evitar la doble no imposición. No obstante, las normas deberían ser capaces de alcanzar dicho objetivo sin generar doble imposición, cargas de cumplimiento injustificadas o restricciones a actividades transfronterizas legítimas. Esta nota explicativa ofrece una visión general del proyecto BEPS y de sus resultados.