The OECD’s publication in October 2015 of the ‘final’ recommendations of the Base Erosion and Profit Shifting (BEPS) project was a milestone in the history of the international tax system. However it quickly became clear that this was only the end of Act 1 in what was to be a long drawn-out production. The two and a half years that had been spent on it would be dwarfed by Act 2 comprising implementation clarification and iteration (the latter referring to some additional standard setting). During this period we have seen: 102 countries joining the BEPS ‘inclusive framework’ making a commitment to implementing the BEPS minimum standards; 70 territories signing the multilateral instrument (MLI) which potentially modifies the terms of a large number of double tax treaties to give effect to BEPS measures; the OECD’s Forum on Harmful Tax Practices continue its work examining compliance with...
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