BEPS (Base Erosion and Profit Shifting)

The OECD/G20 project (launched 2013) addressing strategies that exploit gaps and mismatches in international tax rules to shift profits to low- or no-tax jurisdictions. The 15 BEPS Actions produced specific recommendations on transfer pricing, hybrid mismatches, controlled foreign corporations, treaty shopping, permanent establishments, and country-by-country reporting. Implementation occurred via domestic legislation, the Multilateral Instrument (MLI, 2018), and the EU Anti-Tax Avoidance Directive. BEPS 2.0 (2021-2025) introduced Pillar 1 (re-allocation of taxing rights for the largest multinationals) and Pillar 2 (15% global minimum corporate-tax rate via the GLOBE rules). Pillar 2 entered force in many jurisdictions from 2024-2025; Pillar 1 implementation remains contested. For individuals, BEPS Pillar 2 affects multinational employers and their tax structures rather than personal taxation directly.