This report was produced by the Tax Policy and Statistics Division of the OECD’s Centre for Tax Policy and Administration. It was led by Daniel Fichmann under the supervision of Bert Brys, and written jointly by Daniel Fichmann, Stéphane Buydens, Felix Estgen, Patrice Ollivaud (Economics Department), Ruairi Sugrue, and Astrid Tricaud. The authors would like to thank the delegates of Working Party No.2 on Tax Policy Analysis and Tax Statistics in its Inclusive Framework format and the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) for their inputs, as well as colleagues Piet Battiau, Assia Elgouacem, Pierce O’Reilly, Sarah Perret, and Kurt Van Dender for their contributions and comments. The authors would also like thank Karena Garnier for her assistance with editing and Michael Sharratt for his support with data processing.
The report was approved by the OECD/G20 Inclusive Framework on BEPS on 13 August 2025 and prepared for publication by the OECD Secretariat.