BEPS: OECD insists it is engaging with developing countries

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

BEPS: OECD insists it is engaging with developing countries

beps.jpg

More than 300 senior tax officials from more than 100 jurisdictions and international organisations met in Paris on September 26 and 27 to discuss solutions to unintended double non-taxation caused by base erosion and profit shifting (BEPS).

“Participants discussed the content of the action plan on BEPS released on July 19 and ways through which developing countries can engage and provide input,” said an OECD press release.

“We need to address BEPS issues in order to maintain and strengthen the existing framework to eliminate double taxation, which is key for cross-border investments. The BEPS project is both exciting and challenging and we can work together to achieve concrete results in the next 18-24 months,” said Pascal Saint-Amans, director of the OECD’s Centre for Tax Policy and Administration.

Saint-Amans also commented on the importance of this work for developing countries, noting that corporate income tax revenue makes up a substantial part of their total tax revenues.

Tax justice campaigners including ActionAid have stressed the importance of including developing countries in any process designed to tackle BEPS.

When G20 leaders endorsed the BEPS action plan last month, Toby Quantrill, ActionAid tax policy adviser, said the statement “still gives little assurance that these tax reform processes will respond to the needs of the world’s poorest countries”.

And Keith O’Donnell, Taxand board member and managing partner of Atoz – Taxand Luxembourg, said recent meetings hosted by bodies such as the OECD and G20 have failed to clarify how the BEPS process will include developing countries.

“The result leaves us somewhat unclear as to which is highest up the OECD’s priority list – is the BEPS initiative more about the public’s concern over multinational tax planning, or the concerns arising from profits being diverted away from developing countries?” asks O’Donnell.

Saint-Amans told delegates at the 13th International Tax Review Global Transfer Pricing Forum in New York that the 18-24 month timeframe, which has been criticised by many as too ambitious, will be achievable because of the top-down approach to the BEPS project.

“The BEPS project is being handled by governments and organisations such as the G20, whereas the intangibles project [for example] is being run by a working group involving tax experts involved in the tax market on a daily basis,” he said.

more across site & shared bottom lb ros

More from across our site

A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability
HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires
Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
Gift this article