Action plan

Automatic exchange of Country-by-Country Reports (Action 13)

Controlled foreign companies (Action 3)

Digital economy (Action 1)

Effective dispute resolution, minimum standard (Action 14)

Elimination of double taxation, provisions affecting

Exchange of information on tax rulings (Action 5)

Harmful tax practices (Action 5)

Hybrid mismatch arrangements (Action 2)

Interest deductions and other financial payments (Action 4)

Mandatory disclosure of cross-border tax planning (Action 12)

Minimum standard

Multilateral convention to implement tax treaty related measures (MLI) (Action 15)




Preventing treaty abuse, minimum standard (Action 6)

OECD/G20 project

Action plan

Final reports

Inclusive framework

Minimum standard

Non-member countries

Peer reviews

Principles of treaty interpretation

Provisions affecting distributive rules

Associated enterprises – corresponding adjustments

Capital gains from alienation of shares

Dividend transfer transactions

Permanent establishments situated in third states

Provisions affecting legal status (Action 2)

Savings provision

Transparent entities

Provisions affecting the meaning of permanent establishment (Action 7)


Auxiliary exclusions

Building sites, construction or installation projects

Person closely related to an enterprise

Provisions affecting treaty residence dual resident entities (Action 2)

Treaty abuse (Action 6)