The OECD/G20 Inclusive Framework is currently undertaking a stocktake exercise to examine research and evidence on the economic and behavioural impacts of the BEPS Project, both in aggregate and for each of the 15 Actions. A report will be published ahead of the October G20 meeting in response to the G20 presidency’s request to evaluate how BEPS measures have reshaped international tax systems.
CFE Tax Advisers Europe has published an Opinion Statement in response to the OECD Inclusive Framework’s BEPS Package Stocktake, calling for simplification, proportionality, and balanced implementation to sustain competitiveness and fairness in international taxation.
Executive Summary
- BEPS has significantly aligned profits with real economic activity, enhancing transparency through CbCR, DAC exchanges, and treaty anti-abuse measures.
- The EU led global implementation, adopting BEPS Actions via ATAD 1 & 2 and DAC 1-6, but this leadership has created significant complexity and compliance burdens for businesses.
- Complex anti-avoidance and reporting rules, such as hybrid mismatch provisions and DAC6 hallmarks, have increased compliance costs, created uncertainty, and risk undermining competitiveness without proportional benefits.
- CFE calls for simplification, consolidation of overlapping EU frameworks (e.g. a unified DAC), clearer guidance on rules such as hybrids and interest limitation, and balanced anti-abuse measures that do not penalise genuine business arrangements.
- Improved dispute resolution remains essential, with CFE supporting the EU’s binding arbitration approach under Action 14 while calling for further enhancements to reduce double taxation risks globally.
Opinion
CFE Tax Advisers Europe has submitted this Opinion Statement to the OECD as part of the stocktake exercise, providing practical insights from European tax advisers on the decade-long implementation of BEPS reforms. The stocktake seeks inputs from business stakeholders worldwide on how BEPS Actions have changed international tax systems, examining both economic data and practical experiences to inform evidence-based policymaking.
The CFE submission highlights that while BEPS measures have achieved their objectives of tackling aggressive tax planning and enhancing tax fairness, the resulting complexity, compliance fatigue, and administrative burdens risk undermining these very goals. EU implementation via ATAD and DAC frameworks has set global standards but has also imposed disproportionate burdens on EU businesses compared to non-EU competitors. Detailed anti-hybrid rules, complex interest limitation provisions, and broad mandatory disclosure regimes have led to uncertainty and significant compliance costs, with evidence of “over-reporting” under DAC6 and challenges for SMEs in navigating hybrid mismatch rules.
CFE supports the objectives of BEPS and remains committed to transparency, tax fairness, and effective anti-avoidance. However, it urges policymakers to simplify rules, ensure proportionality, consolidate fragmented legislation (such as DAC amendments), and prioritise tax certainty alongside anti-avoidance goals. Effective dispute resolution mechanisms, including binding arbitration, must be expanded to avoid double taxation and protect business confidence.
The statement concludes by calling on the OECD, EU institutions, and national policymakers to balance transparency and anti-avoidance with administrative feasibility, competitiveness, and taxpayer certainty. CFE stands ready to engage with stakeholders to build a fair, effective, and sustainable international tax framework that fosters compliance while enabling economic growth.
We invite you to read the full statement and remain available for any queries concerning its content.