The Global Tax Advisers Platform (GTAP) has published an Opinion Statement by way of submission to the OECD Inclusive Framework’s BEPS stocktake exercise. The stocktake will evaluate the economic and behavioural impacts of the BEPS Project, with a report due ahead of the October G20 meeting.
GTAP’s submission acknowledges that BEPS has driven substantial behavioural changes in multinational enterprises, notably encouraging enhanced documentation, greater alignment of profits with economic substance, and reduced reliance on debt-heavy financing structures. Actions such as transfer pricing reforms, permanent establishment rules, and interest deductibility limitations have shaped how businesses structure their operations, allocate capital, and manage tax risk.
However, GTAP emphasises that implementation has been uneven globally, with developing countries facing significant capacity challenges. The response highlights the need for targeted technical assistance, phased implementation, and stronger inclusion of Global South perspectives to ensure fairness, equity, and practicality in international tax reform. GTAP also stresses the importance of embedding tax governance at board level to promote ethical practices, compliance, and stakeholder trust.
In its recommendations, GTAP calls for improvements to dispute resolution mechanisms to enhance tax certainty, further simplification to reduce administrative burdens, and more consistent interpretation of BEPS rules across jurisdictions. It also notes the importance of integrating ESG considerations into tax policy and future-proofing frameworks to adapt to evolving business models and technological change.
The submission concludes by reaffirming GTAP’s commitment to supporting a fair, efficient, and inclusive global tax system that recognises the rights of taxpayers and the vital role of tax professionals worldwide.
We invite you to read the Statement and remain available for any queries.