使争端解决更加有效——简化同行评审，圣卢西亚（第一阶段）：BEPS包容性框架：行动14

Making Dispute Resolution MoreEffective – Simplified Peer Review,Saint Lucia (Stage 1) Inclusive Framework onBEPS: Action 14 OECD/G20 Base Erosion and Profit Shifting Project Making Dispute ResolutionMore Effective – SimplifiedPeer Review, Saint Lucia(Stage 1) INCLUSIVE FRAMEWORK ON BEPS: ACTION 14 This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty overany territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Photo credits:Cover © ninog-Fotolia.com. Corrigenda to OECD publications may be found at: https://www.oecd.org/en/publications/support/corrigenda.html.© OECD 2025 Attribution 4.0 International (CC BY 4.0) This work is made available under the Creative Commons Attribution 4.0 International licence. By using this work, you accept to be bound by the terms of this licence(https://creativecommons.org/licenses/by/4.0/).Attribution– you must cite the work.Translations– you must cite the original work, identify changes to the original and add the following text:In the event of any discrepancy between the original work and thetranslation, only the text of original work should be considered valid.Adaptations– you must cite the original work and add the following text:This is an adaptation of an original work by the OECD. The opinions expressed and arguments employed inthis adaptation should not be reported as representing the official views of the OECD or of its Member countries.Third-party material– the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party and forany claims of infringement.You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your use of the work.Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration (PCA) Arbitration Rules 2012. The seat of arbitration shallbe Paris (France). The number of arbitrators shall be one. Foreword Digitalisation and globalisation have had a profound impact on economies and the lives of people aroundthe world, and this impact has only accelerated in the 21st century. These changes have brought with themchallenges to the rules for taxing international business income, which have prevailed for more than ahundred years and created opportunities for base erosion and profit shifting (BEPS), requiring bold movesby policy makers to restore confidence in the system and ensure that profits are taxed whereeconomicactivities take place and value is created. In 2013, the OECD ramped up efforts to address these challenges in response to growing public andpolitical concerns about tax avoidance by large multinationals. The OECD and G20 countries joined forcesand developed an Action Plan to address BEPS in September 2013. The Action Plan identified 15 actionsaimed at introducing coherence in the domestic rules that affect cross-border activities, reinforcingsubstance requirements in the existing international standards, and improving transparency as well ascertainty. After two years of work, measures in response to the 15 actions, including those published in an interimform in 2014, were consolidated into a comprehensive package and delivered to G20 Leadersin November2015. The BEPS package represents the first substantial renovation of the international tax rules in almosta century. As the BEPS measures are implemented, it is expected that profits will be reported where theeconomic activities that generate them are carried out and where value is created. BEPS planningstrategies that rely on outdated rules or on poorly co-ordinated domestic measures will be renderedineffective. OECD and G20 countries also agreed to continue to work together to ensure a consistent and co-ordinatedimplementation of the BEPS recommendations and to make the project more inclusive. As a result, theycreated the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), bringing all interested andcommitted countries and jurisdictions on an equal footing in the Committee on Fiscal Affairs and itssubsidiary bodies. With over 140 members, the Inclusive Framework monitors and peer reviews theimplementation of the minimum standards and is completing the work on standard settingto address BEPSissues. In addition to its members, other international organisations and regional tax bodies are involvedin the work of the Inclusive Framework, which also consults business and the civil society on its differentwork streams. Although implementation of the BEPS package is dramatically changing the international tax landscapeand improving the fairness of tax systems, one of the key outstanding BEPS issues–to address the taxchallenges arising from the digitalisation of the economy–remained unresolved. In a major step forwardon 8 October 2021, over 135 Inclu