BEPS (Base Erosion and Profit Shifting)
BEPS stands for Base Erosion and Profit Shifting. It is both the umbrella term for the strategies multinationals use to exploit gaps and mismatches between countries' tax rules, and the name of the OECD/G20 reform project launched to curb them. The OECD launched the BEPS Action Plan in 2013 and delivered 15 actions by 2015, covering transfer pricing documentation, country-by-country reporting and rules on hybrid mismatches. Despite the reforms, the Tax Justice Network's State of Tax Justice 2024 found remarkably little change in the volume of profit shifting between 2016 and 2021. A second round, Pillars One and Two, followed but remains incomplete.
ByLoopholeKiln EditorialPublished
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Example: the now-closed "Double Irish" was a classic BEPS structure, routing profit through two Irish entities engineered to be tax-resident nowhere.
Why it matters to a small business: BEPS tools are out of reach for any small firm. You have no multinational group, no portable intellectual property and no budget for the advisers these arrangements are built around. The reform project is aimed at a problem you are not part of and cannot benefit from.