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OECD Reports On BEPS Minimum Standards Implementation

Wednesday 22nd April 2026

The OECD has issued its report on recent developments in international tax co-operation, including support of G20 priorities such as the implementation of the BEPS minimum standards, the global minimum tax framework, and tax transparency ahead of the First G20 Finance Ministers and Central Bank Governors’ Meeting under the United States G20 Presidency, held on 16 April 2026.

The report includes a technical update on progress regarding implementation of the BEPS minimum standards in Annex A.

Action 5 – Harmful Tax Practices

The Action 5 minimum standard addresses harmful tax practices through peer review, ensuring that preferential tax regimes do not facilitate BEPS or attract profits without real economic activity, and by ensuring transparency through the exchange of information on certain tax rulings.

  • Transparency framework: peer review assessments are carried out annually on almost 140 jurisdictions. When the BEPS Package was issued, virtually no information on tax rulings was being exchanged. The latest peer review results were published in December 2025. Based on recent data, over 64,000 exchanges of rulings have taken place.
  • Preferential regimes: the Forum on Harmful Tax Practices (FHTP) has released its latest regime review results in February and has now reviewed 326 regimes, with over 40% of those regimes being abolished. The latest review was the first one done in line with the revised methodology, adopted by the OECD/G20 Inclusive Framework in April 2025, that ensures that the BEPS-impact of a regime is first assessed prior to a legislative review by the FHTP. In 2026, the FHTP will continue its regime reviews in line with the revised methodology.
  • No or only nominal tax jurisdictions: the 11 no or nominal tax jurisdictions have been reviewed under Action 5 for the fifth consecutive year and have all introduced economic substance requirements. The next annual monitoring exercise for no or only nominal tax jurisdictions will take place in the second half of 2026.

Action 6 – Tax Treaty Abuse

The Action 6 minimum standard is focused on strengthening tax treaties with anti-abuse measures to ensure that they do not create opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements. Preventing treaty abuse helps to more closely align the allocation of income between countries with the economic activity that generates that income.

Implementation of the Action 6 minimum standard in tax treaties is at an advanced stage primarily through the use of the BEPS MLI, with most newly concluded tax treaties now also including provisions implementing the Action 6 minimum standard.

To date, the BEPS MLI covers 107 jurisdictions of which 90 have already ratified and over 2,000 bilateral tax treaties. The MLI has already effectively modified over 1,600 of those bilateral tax treaties with approximately 400 additional treaties to be effectively modified once all Signatories ratify. Most jurisdictions that have signed the BEPS MLI have listed all, or almost all, of their tax treaties to be covered.

At this stage more than 90% of the tax treaties concluded between members of the IF are either compliant with the minimum standard, subject to a complying instrument, or subject to steps taken by at least one treaty partner to implement the minimum standard.

Action 13 – Country-by-Country reporting

Action 13 requires all large multinationals to prepare a CbC report with aggregate data on the global allocation of income, profit, taxes paid and economic activity in all tax jurisdictions in which it operates. The CbC report is then shared with qualifying tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments.

As a result of Action 13, over 120 IF members have introduced legislation to require the filing of a CbC report, covering substantially all MNEs above the EUR 750 million threshold.  106 IF members are automatically exchanging CbC reports filed in their jurisdiction with other members that meet the conditions under the standard, and  84 IF members have completed all of the building blocks to enable them to be in a position to receive CbC reports on exchange.

The eighth annual peer review report of Action 13, which considers all aspects of implementation of the CbC Reporting minimum standard by 142 IF members as of 31 March 2025, was released in September 2025. This shows that, where a jurisdiction has legislation in place, the implementation of CbC Reporting has been largely consistent with the Action 13 minimum standard. In particular, since the previous peer review report was released in 2024, 16 jurisdictions have taken steps which followed one or more recommendations for improvements to their domestic legal and administrative framework, their exchange of information framework, or their controls over the appropriate use of CbC reports, enabling these recommendations to be removed. The ninth annual peer review is currently underway and the results are expected to be released in September 2026.

The OECD has provided extensive support, including targeted multilateral workshops on technical issues, to developing countries in their implementation of the Action 13 minimum standard. In total, 28 developing countries now have CbC reporting fully in place, plus a further two jurisdictions that were developing countries at the time they implemented CbC reporting, but which have since been re-categorised as high-income jurisdictions, including 13 that completed the steps to receive CbC reports since the G20/OECD Roadmap on Developing Countries and International Taxation Update was released in July 2023.

Work is also underway to make sure that the information in CbC reports exchanged under Action 13 can be put to effective use, including through workshops, training events, risk assessment software, handbooks and guidance.

Action 14 – Mutual Agreement Procedure

The Action 14 minimum standard aims to ensure that dispute resolution mechanisms in tax treaties operate effectively. This is achieved through a peer review process designed to assess how jurisdictions comply with the standard.

Under this framework, IF members are assessed based on their ability to prevent disputes, the availability and access to MAP, the resolution of MAP cases, and the implementation of MAP agreements. Beyond assessment, the peer review process serves as an opportunity to provide jurisdictions with recommendations, guidance, and ongoing support to help them meet the standard. Peer reviews began in 2016, initially focusing on jurisdictions with significant MAP experience.

Following the completion of these reviews in 2022 with each jurisdiction being reviewed in two stages, these jurisdictions are now subject to a full peer review every four years to monitor their progress and are encouraged to use the feedback to further refine their MAP policies and practices. Since 2022, jurisdictions with limited MAP experience have been subject to a simplified peer review process which helps them develop policies, share information, and build capacity for future MAP cases, with support from the FTA MAP Forum.

Key outcomes of Action 14:

  • 82 jurisdictions have completed two stages of peer review. A full peer review process is currently underway to assess the progress achieved by 55 jurisdictions with meaningful MAP experience in meeting the Action 14 minimum standard. Reviews have been started for 44 of these jurisdictions. Of these, reviews for 18 have been completed, with final reports already published for four and expected soon for the remaining 12.
  • 77 jurisdictions with limited or no MAP experience have undergone or are undergoing a simplified peer review process. Reports for 60 of these jurisdictions have already been published and the remaining 17 jurisdictions are undergoing peer review. The simplified peer review process aims to help these jurisdictions to set up a more robust MAP programme for a possible increase in cases in the future.

Jurisdictions also report statistics related to their tax certainty obligations under Action 14. Ongoing collection of data provides a clearer picture of implementation and ensures transparency through published information on MAP, for example MAP guidance or MAP profiles are available through the annual Consolidated Information on MAP. Starting in 2024, jurisdictions have also begun reporting statistics on Advance Pricing Arrangements, offering stakeholders deeper insights into the functioning of dispute prevention mechanisms within each jurisdiction.

If you would like more detail on the above, please contact Keith Rushen on 0207 486 2378.

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