OECD: Revised framework for exchange of information on tax rulings under BEPS Action 5

Revised methodology for peer reviews starting in 2026

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September 8, 2025

The OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) today released a revised framework for the exchange of information on tax rulings under BEPS Action 5.

According to the OECD release (September 8, 2025), the revised framework reflects the outcomes of a review of the framework’s effectiveness and provides a revised assessment methodology for peer reviews starting in 2026, as well as a revised exchange on tax rulings (ETR) XML schema and related user guide that must be used for all exchanges from January 1, 2027.

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