(1) Digital Economy

Based on the characteristics of business model under digital economy, BEPS re-examines the current tax system, tax treaty, and the existing problems in the transfer pricing rules, and suggests adjustments for domestic legislation and international rules.

(2) Hybrid Mismatch Arrangements

Based on the model of tax planning comparing two countries or multinational tax system difference, BEPS proposes adjustments for domestic legislation and international rules.

(3) Controlled Foreign Company Rules

BEPS makes suggestions on how to strengthen the controlled foreign company profits tax rules.

(4) Interest Deduction

Based on the difficulties in claiming the interest deduction and financial instruments, BEPS recommends adjustments for the domestic legislation and international rules. This work coordinates with hybrid mismatch arrangements and controlled foreign company rules.

(5) Unfavourable Tax Practices

BEPS takes into consideration preferential tax system of the OECD members and non-members and facilitates different countries to improve or abolish the unfavourable preferential income tax system, putting forward suggestions to solve the issue of unhealthy tax competition at the same time.

(6) The abuse of tax treaty

Based on various abuse treatment agreements, on one hand, revise and make clear the tax treaty; on the other hand, make necessary revision to domestic law revision, which can prevent the abuse of tax treaty.

(7) Permanent Establishment

BEPS should make a revision to the provision of permanent establishment in tax treaty to mitigate the negative implications.

(8) Intangible Assets, Risk and Capital as well as other High-Risk Transactions

BEPS draw up rules to avoid intra-company and associated enterprises' behavior of tax avoidance through the intangible assets, human distribution of risk and capital transferring profits to the local region.

(9) The Statistical Analysis

Build data collection and analysis indicator system, designed for monitoring and early warning indicators of BEPS behavior, conduct analysis to estimate the size and economic impact of BEPS behavior.

(10) Principle of Mandatory Disclosure

Helping countries to design disclosure mechanisms for tax planning scheme disclosure mechanisms (including nature of transaction and disclosure of the way, and the information related to the use of sanctions, etc.), to strengthen the supervision of the tax authorities for tax risk management and prevention.

(11) Transfer Pricing Documentation

The development of generic template on transfer pricing documentation will improve tax transparency, reduce compliance cost and lighten the burden on taxpayers.

(12) Dispute Settlement

The action plan aims to establish a more effective dispute settlement mechanism, to avoid double taxation of cross-border investors.

(13) Multilateral Tool

In order to expedite the implementation of the action plan, the results of research to develop a multilateral agreement on the existing terms of the agreement be revised and improved.