On 19 July 2013, the OECD published its Action Plan on Base Erosion and Profit Shifting (BEPS).

The BEPS Action Plan was designed to improve the international tax system in light of the challenges presented by globalisation. Across 15 actions, it sought to put an end to double non-taxation through hybrid mismatch arrangements; to limit base erosion via interest deductions; to address the abuse of tax treaties and the weaknesses of transfer pricing rules; to increase transparency between taxpayers and tax administrations, and to establish more effective dispute resolution mechanisms.

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