Base Erosion and Profit Shifting BEPS
Stands for: Base Erosion and Profit Shifting
The OECD-led project addressing tax planning strategies that exploit gaps and mismatches between tax rules to shift profits to low-tax locations.
Definition
What it is
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 versus 2.0
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.
Why it matters
BEPS reshaped substance requirements, documentation, and treaty access. Founders building international structures must consider BEPS-driven rules from day one, not retrofit them later.
When you'll encounter it
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.
Used in our guides
- Turkey Double Taxation Treaties: Complete List and How to Use Them
- UAE Business Laws and Compliance: Essential Guide for Foreign Companies
- UAE Corporate Tax 2026: Complete Guide to the New 9% Rate
- Singapore Tax Incentives for Startups: Pioneer, Development, and IP Programs
- Holding Company Structure Explained With Examples in 2026
FAQ
Is BEPS binding law?
BEPS itself is a policy framework. The legal effect comes through domestic legislation, EU directives (ATAD I and II), and the OECD Multilateral Instrument (MLI).
What is the MLI?
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS, which simultaneously amends thousands of bilateral tax treaties without renegotiating each one.
Does BEPS apply to small groups?
Many BEPS measures (PPT, hybrid-mismatch rules, ATAD provisions) apply regardless of size. Country-by-country reporting is the main rule with a clear EUR 750m revenue threshold.
References
- OECD - BEPS Project https://www.oecd.org/tax/beps/
- OECD - Multilateral Instrument (MLI) https://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-beps.htm