This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.

The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 4.

Although the concept of international public goods has been established, new international public needs arise by the day. For example, while there are many taxation problems and debates that have not yet been resolved internationally, many new tax-related problems like international transfer pricing, taxation of virtual profits, and taxation of electronic commerce are being added. These issues require studies that will discuss a new agenda and propose solutions for these dilemmas and problems. Global Challenges in Public Finance and International Relations provides an innovative and systematic examination of the present international financial events and institutions, international financial relations, and fiscal difficulties and dilemmas in order to discuss solutions for potential problems in the postmodern world. Highlighting topics such as international aid, public debt, and corporate governance, this publication is designed for executives, academicians, researchers, and students of public finance.