OECD: BEPS Action 11 (improving analysis of BEPS)

OECD: BEPS Action 11 (improving analysis of BEPS)

The Organisation for Economic Co-operation and Development (OECD) published a “discussion draft” as a deliverable under the base erosion and profit shifting (BEPS) project on improving the analysis of BEPS.


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Read the BEPS Action 11 discussion draft [PDF 1.89 MB]


BEPS Action 11 calls to establish methodologies to collect and analyze data on BEPS and the actions to address it. This involves:

  • Developing an economic analysis of the scale and impact of BEPS and actions to address it
  • Assessing a range of existing data sources
  • Identifying new types of data to be collected
  • Developing methodologies based on both aggregate and micro-level data


The Working Committee assigned to BEPS Action 11 reviewed existing data on BEPS and BEPS countermeasures, and with the discussion draft, provided an initial evaluation of the current state.

The discussion draft poses some questions about the data required for analysis around BEPS and BEPS countermeasures in the future as well as provides certain recommendations for “indicators of the scale (fiscal effects) and economic impacts of BEPS.”

The discussion draft identifies specific questions when input is required to advance the work on BEPS Action 11.

  • What is the data currently available to analyze BEPS and BEPS countermeasures?
  • What are governments’ best practices in collecting data and making data available for research?
  • Are there additional indicators of BEPS that might be provided?
  • Could the proposed indicators have their “signal-to-noise” ratio enhanced?
  • Are there additional empirical analyses of BEPS and BEPS countermeasures, particularly in developing countries?
  • Are there alternative approaches or refinements of the two proposed approaches to estimating the scale of BEPS?
The OECD is clear in saying that the content of this discussion draft does not represent conclusions, but is intended to provide content for analysis and comment.
This discussion draft includes three chapters:
  • Chapter 1 is an assessment of existing data sources relevant for BEPS analysis, describing the available data and their limitations for undertaking an economic analysis of the scale and impact of BEPS and BEPS countermeasures.
  • Chapter 2 provides potential indicators of the scale and economic impact of BEPS and their various strengths and limitations.
  • Chapter 3 sets existing empirical analyses of BEPS and proposes two complementary approaches to estimating the scale of BEPS.

What’s next?

The OECD is requesting comments on the discussion draft to be submitted by 8 May 2015 and it intends to hold further public consultation on the discussion draft on 18 May 2015 at the OECD Conference Center in Paris, France. The BEPS Action Plan calls for this work to be completed by September 2015.

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