OECD: Exchange of information on tax rulings under BEPS Action 5
Eighth annual peer review of the implementation of BEPS Action 5 minimum standard on tax rulings
The OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) has released the latest peer review assessments for 136 jurisdictions concerning the spontaneous exchange of information on tax rulings.
According to the OECD release (December 16, 2024), this marks the eighth annual peer review of the implementation of BEPS Action 5 minimum standard on tax rulings, which is designed to equip tax administrations with essential information to combat tax avoidance and other BEPS risks.
The 2023 Peer Review Reports on the Exchange of Information on Tax Rulings indicates that over 58,000 exchanges of information have occurred regarding more than 26,000 identified tax rulings. Specifically, in 2023, over 4,600 exchanges were conducted for nearly 2,000 tax rulings. These figures highlight the high compliance level among Inclusive Framework members with the BEPS Action 5 minimum standard and emphasize the significance of a global policy for transparency and information exchange on tax rulings.
The peer review results show that 104 jurisdictions fully comply with the BEPS Action 5 minimum standard, while the remaining 32 jurisdictions received 56 recommendations to enhance their legal or operational frameworks. This feedback has prompted several jurisdictions to revise their processes and improve the clarity and quality of exchanged information.