Base erosion and profit shifting is being implement by the countries that are signing the Multilateral Instrument. The MLI shall enter into force on 1 July 2018.

Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Under the inclusive framework, over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS.
multilateral-instrument-BEPS-tax-treaty-information-brochure

Source: OECD

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