In response to concerns that the international tax system had not kept pace with globalisation and digitalisation of the economy, the OECD undertook its base erosion and profit shifting (BEPS) project from 2013 to 2015. This resulted in detailed recommendations designed to reduce the opportunities for multinational companies to shelter profits from taxation.

The recommendations were accompanied by new country by country reporting requirements for large companies, specific guidance on new transfer pricing documentation and dispute resolution measures.

These outcomes from the project have been widely implemented.