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OECD: Peer review results on BEPS Action 5

Ninth annual peer review under the BEPS Action 5 minimum standard

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december 18, 2025

The Inclusive Framework on BEPS yesterday released the latest peer review results for 139 jurisdictions concerning the spontaneous exchange of information on tax rulings. This marks the ninth annual peer review under the BEPS Action 5 minimum standard, aimed at providing tax administrations with essential information to address tax avoidance and base erosion and profit shifting (BEPS) risks.

According to the OECD release (December 17, 2025), the 2024 peer review reports revealed that:

  • Over 64,000 exchanges of information have occurred regarding more than 28,500 tax rulings identified to date.
  • In 2024, there were over 5,500 exchanges related to nearly 2,300 identified tax rulings.
  • 113 jurisdictions fully comply with the BEPS Action 5 minimum standard, while 26 jurisdictions received 46 recommendations for improvement.

The next peer review round is scheduled for 2027, covering 2025 and 2026.

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