Introduction and background: 15 actions, dozens of questions.

• Author: Levin-Epstein, Michael
• Position: The Organisation for Economic Co-operation and Development's Base Erosion and Profit Shifting Final Report, part 1 - Cover story

Maybe the anticipation didn't reach that of ardent fans waiting for the trailer to the next Star Wars movie. And maybe it didn't rival that of passionate followers of Harry Potter breathlessly lining up at midnight to make sure they could score a copy of the latest J.K. Rowling opus. But, for most TEI members, the release of the OECD's BEPS (base erosion and profit shifting) final report issued by the Organisation for Economic Co-operation and Development in October--in terms of making a meaningful dent in lives--probably rivaled what ardent fans of the teams that will be playing in Super Bowl 50 will experience.

The work to address BEPS is based on the 2013 G20/OECD BEPS Action Plan, which identified fifteen actions generally aimed at putting an end to international tax avoidance. The plan was structured around three fundamental pillars, according to those drafting the final report:

* Introducing coherence in the domestic rules that affect cross-border activities.

* Reinforcing substance requirements in the existing international standards to ensure alignment of taxation with the location of economic activity and value creation.

* Improving transparency, as well as certainty for businesses and governments.

The BEPS measures were agreed upon after an intensive, two-year consultation process among OECD, G20, and developing countries and stakeholders from business, labor, academia, and civil society organizations.

The OECD presented the BEPS measures to G20 finance ministers during the meeting hosted by Turkeys Deputy Prime Minister Cevdet Yilmaz on October 8 in Lima, Peru.

As we go to press, the focus now shifts to designing and putting in place an inclusive framework for monitoring BEPS and supporting implementation of the measures, with all interested countries and jurisdictions invited to participate on an equal footing, according to those participating in the release of the report.

The final package of BEPS measures includes new minimum standards on country-by-country reporting, which for the first time will give tax administrations a global picture of the operations of multinational enterprises; treaty shopping, to put an end to the use of conduit companies to channel investments; curbing harmful tax practices, in particular, in the area of intellectual property and through automatic exchange of tax rulings; and effective mutual agreement procedures, to help ensure that the fight against double nontaxation does not result in double...