Published on 10 January 2025
OECD
Working partys and Forum
Working partys
The main task of working group 1 is to seek solutions to improve the OECD Model Convention on the avoidance of double taxation.
Working Group 1 is currently dealing with various aspects of the two-pillar solution of the Inclusive Framework on BEPS (IF). These include the implementation of the subject-to-tax rule (STTR) in double taxation agreements (DTAs) and the question of the GloBE minimum taxation rules' compliance with DTAs. Working Group 1 is also responsible for the development of a multilateral agreement for the resolution of disputes regarding the application of the GloBE minimum taxation rules. Another important topic for Working Group 1 is the question of how to avoid double taxation due to the increasing mobility of employees, in particular the establishment of a home office. The development of an (optional) provision for the allocation of taxing rights for companies active in the extraction of raw materials, measures to increase legal certainty in the application of the principal purpose test (PPT) rule and clarifications for the avoidance of double taxation of profits of associated enterprises are further topics currently being addressed by Working Group 1.
Most of the work of Working Group 1 is to be incorporated into the next edition of the OECD Model Tax Convention and its commentary, which is to be published in 2025.
The main task of working party no. 2 is to analyse current topics in tax policy. Working party no. 2 usually meets twice a year.
The working party is responsible for numerous publications published annually:
- The "Tax Policy Reforms in the OECD" publication was first published in 2016 and provides an overview of significant changes in all tax matters.
- The "Revenue statistics" publication presents a series of detailed and internationally comparable data in a common format for all OECD member states since 1965 and has now been extended to 125 countries. Each "Revenue statistics" also contains a special topic.
- The "Taxing wages" publication compares the evolution of wages before and after taxes and certain social contributions for different household constellations and income levels in each country and contains information on taxes paid on wages in OECD countries. This publication also contains a special topic in each edition.
Furthermore, the working party no. 2 maintains a tax database which is publicly available online. This provides comparative information on a range of tax statistics such as tax receipts, income taxes, non-tax levies, corporate and capital taxes and consumption taxes in the 35 OECD countries.
Finally, working party no. 2 is continuing its work on action 11 of the BEPS action plan and is particularly concerned with the existing databases and indicators for measuring the BEPS phenomenon. The publication ‹Corporate Tax Statistics› is the result of this work. In addition to publicly available data on corporate taxation, it also presents aggregated information on country-by-country reporting. The publication provides insights into the global tax payments and economic activities of large multinational companies.
- The "Tax Policy Reforms in the OECD" publication was first published in 2016 and provides an overview of significant changes in all tax matters.
The mandate of Working Party 6 is to address transfer pricing issues with the aim of updating and improving the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG).
A new edition of the OECD TPG was published in January 2022, which includes the revised guidelines for applying the transaction-specific profit method, the guidelines for tax administrations on applying the approach for ‹hard-to-value intangibles› agreed in 2018, and the new transfer pricing guidelines for financial transactions adopted in 2020.
Working group 6 is currently working on various aspects of Amount B of Pillar 1 of the IF's two-pillar solution and its implementation under the OECD TPG. These include, among other things, the final report on Pillar 1, Amount B, which was published on 19 February 2024 and included as an appendix to Chapter IV of the OECD TPG, as well as the guidelines on the outstanding definitions of ‹qualifying jurisdictions› and ‹low-capacity jurisdictions›, which were published in June 2024.
Another important topic, which overlaps with the tasks of Working Party 1, concerns the impact of the increasing mobility of employees on transfer pricing and the question of profit allocation in the case of a home office permanent establishment.
Following the adoption of the International VAT Guidelines by the OECD Council in September 2016, working party no. 9 drafted a report on the implementation of the guidelines published in October 2017. In the first chapter, different possibilities of value-added taxation in the country of destination are presented. The second chapter deals with issues relating to the collection of tax from companies not established in the country of destination and the third chapter deals with simplified registration for companies not established in the country of destination. The role of digital platforms in the value-added taxation of online offerings is now a key issue that a sub-group with Swiss participation is dealing with. Working party no. 9 usually meets twice a year.
Working party no. 10 develops the legal and technical regulations for the international exchange of information, deals with their further development and thus ensures the effectiveness of the international exchange of information standards. One part of this work is a joint action plan to combat loopholes in the global standard for the automatic exchange of financial account information. Working party no. 10 usually meets twice a year.
Working party no. 11 was formed as part of the BEPS project. It is responsible for the following four actions of the BEPS project: neutralise the effects of hybrid mismatch arrangements (action 2), strengthen controlled foreign company rules (CFC rules, action 3), limit base erosion via interest deductions and other financial payments (action 4) and require taxpayers to disclose their aggressive tax planning arrangements (action 12). Working party no. 11 usually meets twice a year.
Since the adoption of the final reports in October 2015, working party no. 11 has undertaken further work on specific points. In December 2016, for example, additional clarifications were published in connection with the limitation of interest deductions (action 4; regulation of the permissible deduction rate at group level and the application of the rules limiting interest deductions to the banking and insurance sectors). In addition, expert comments were published in August 2017 on hybrid mismatch arrangements (action 2) which identified hybrid mismatch arrangements with branches and sets out rules to harmonise their treatment with the recommendations from the final report on BEPS action 2. In addition, working party no. 11 participated in the work of working party no. 10 on model disclosure rules for intermediaries.
Forum
The Forum on Harmful Tax Practices began reviewing the minimum standard for transparency of advance tax rulings, as well as the minimum standard for patent boxes and comparable tax regimes (BEPS action 5) in 2017. The Forum meets on average twice a year.
A progress report on the implementation of the minimum standard for patent boxes and similar regimes was published in October 2017. The list and status of the regimes are regularly updated.
The implementation of the minimum standard for the transparency of advance rulings in tax matters is subject to annual reviews. The first review report, which covers the year 2016, was published in December 2017.
The Forum on Tax Administration (FTA), founded in 2002, brings together heads of tax administrations from over 50 OECD and non-OECD countries. The FTA's work programme and activities currently focus on implementing the BEPS project, the digital transformation of tax administrations, and improving the capacities of tax administrations in developing countries.
The Tax Administration Series (TAS) publication provides an insight into the various tax administrations and thus allows for comparisons (link: Comparative analysis of tax administrations | OECD). The underlying data set comes from the International Survey on Revenue Administration (ISORA) (link: Revenue Administrations Fiscal Information Tool - Home - ISORA (rafit.org)). A wide range of data, analysis and country examples are used in the TAS publication to cover the most important aspects of tax administrations (organisation, tax burden and collection, strategic priorities, risks, etc.). It also highlights current (technical) trends and reforms.
The FTA also focuses on improving the practical implementation of mutual agreement procedures (MAP). The FTA MAP Forum is particularly important in the context of the BEPS project, as it reviews the implementation of the standard for dispute resolution in double taxation cases (Action 14). As part of the OECD Tax Certainty Days, MAP statistics are published annually and MAP Awards are presented.
Media
20 October 2025
Switzerland and EU sign Amending Protocol to the Agreement on automatic exchange of information in tax matters
On 20 October 2025 in Brussels, Switzerland and the European Union (EU) signed the Amending Protocol to the Agreement on the automatic exchange of financial account information to improve international tax compliance. With the Amending Protocol, the Agreement will be aligned to the amended OECD standard and supplemented with new provisions on administrative assistance for the collection of VAT claims.