On 5 October 2015, the Organisation for Economic Co-operation and Development (OECD) released the final package of measures under the Base Erosion and Profit Shifting (BEPS) project.  Read about the background to the BEPS project, implementation by countries and companies and the 18 submissions made by the Institute relating to BEPS

The package provides a comprehensive framework of international standards and recommendations to help address the BEPS concerns identified by the OECD in their 15-point Action Plan of July 2013.  The package, which consists of 13 Reports in total, can be found here.

The focus is now on the implementation of the BEPS measures, as countries internationally introduce changes to their domestic law to underpin the BEPS changes. Ireland signed the Multi-lateral Instrument (MLI) on 7 June 2017 in Paris to implement tax treaty-related measures preventing BEPS. In June 2017, the Department of Finance published a Technical Briefing Note – Ireland’s approach to the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS.

Irish Tax Institute Analysis

The Institute made 18 submissions relating to the BEPS project and we have set out here the most recent submissions

September 2016 – Submission on BEPS Action 7: Attribution of Profits to Permanent Establishments

September 2016 – Submission on Revised Guidance on Profit Split

July 2016 – Submission on BEPS Action 15: Multilateral Instrument

June 2015 – Submission on BEPS Action 6: Preventing Treaty Abuse

June 2015 – Submission on BEPS Action 8: Hard-To-Value intangibles


View more submissions