Monitoring Mechanism for the Implementation of the Minimum Standards






Members of the Inclusive Framework will develop a monitoring process for the four minimum standards as well as put in place the review mechanisms for other elements of the BEPS Package. The monitoring of the four minimum standards will ensure that all members, as well as jurisdictions of relevance, will comply with the standards in order to ensure a level playing field. 




The 4 Minimum standards 


The 4 BEPS Minimum Standards to which the members of the Inclusive Framework must conform are:

  • BEPS Action 5 - Combat harmful tax practices [read]
  • BEPS Action 6 - Preventing the Granting of Treaty Benefits in Inappropriate Circumstances [read]
  • BEPS Action 13 - Guidance on Country-by-Country Reporting [read]
  • BEPS Action 14 - Making Dispute Resolution Mechanisms More Effective [read]


It is noted that the following articles of the Multilateral Instrument (the MLI) all come under the scope of the minimum standards of the OECD/G20 BEPS package:

  • Article 6 (Purpose of a Covered Tax Agreement),
  • Article 7 (Prevention of Treaty Abuse),
  • and Article 16 (Improving Dispute Resolution).

If a contracting jurisdiction is to meet the minimum standards, it is necessary for it to fully adopt the above-mentioned articles to their CTA's.




Peer Review


Action 5 Harmful Tax Practice, Peer Review Reports

  • 2018 progress report on preferential regime [read]
  • 2017 progress report on preferential regime [read]

​Action 6 Preventing Tax Treaty Abuse, 

  • Peer review report [read]

Action 13 Country-by-Country Reporting

  • CbC reporting - first peer review report [read]
  • CbC reporting - second peer review report [read]

Action 14 - Mutual Agreement Procedure, MAP Peer Review Reports

  • Hong Kong [read]
  • China [read]
  • Singapore [read]
  • Other members of the Inclusive Framework [read]