Base Erosion and Profit Shifting is the OECD-led project addressing tax planning strategies that exploit gaps and mismatches between tax rules to shift profits to low-tax locations.
Base Erosion and Profit Shifting (BEPS) refers both to the underlying problem (multinationals using mismatches in international tax rules to reduce their effective tax rate) and to the OECD/G20 policy response.
The original 2015 BEPS package contained 15 Actions covering hybrid mismatches, CFC rules, interest deductibility, harmful tax practices, treaty abuse, permanent establishments, transfer pricing, country-by-country reporting, and dispute resolution.
BEPS 1.0 (2013-2015) produced concrete recommendations now embedded in domestic law and the Multilateral Instrument (MLI), which amended thousands of bilateral tax treaties at once.
BEPS 2.0 (the Two-Pillar Solution, 2021 onwards) tackles the digital economy and tax competition: Pillar One reallocates a portion of residual profit to market jurisdictions, and Pillar Two introduces a 15% global minimum effective tax rate via the GloBE rules.
BEPS reshaped substance requirements, documentation, and treaty access. Founders building international structures must consider BEPS-driven rules from day one, not retrofit them later.
You will see BEPS rules in action whenever you build a cross-border holding structure, consider an IP-holding company, sign intra-group loans subject to interest-limitation rules, or scope country-by-country reporting once revenue crosses EUR 750m. BEPS-aligned anti-abuse clauses also feature in modern tax treaties.
See what a company actually costs in year one, and how the jurisdictions compare on tax, capital and timeline.
