BEPS Inclusive Framework (147+ Jurisdictions)

The Inclusive Framework on BEPS is a global cooperation platform of the OECD and G20 that allows all interested jurisdictions to participate on an equal footing in the development and implementation of BEPS measures. It was established in 2016 to open the BEPS work — originally confined to OECD and G20 members — to all states.

Members commit to implementing the four BEPS minimum standards (Actions 5, 6, 13, 14) and participating in peer reviews. The Inclusive Framework is also the body that negotiated the Two-Pillar Solution (Pillar 1 and Pillar 2) for taxing the digital economy. Today the IF counts over 147 members (as of early 2025).

The BEPS project was launched in 2013 by the G20 and OECD, with voting rights confined to their members. Developing countries criticised this exclusion. At the G20 Finance Ministers meeting in Lima in October 2015, the G20 mandated the OECD to create an open, inclusive participation format enabling non-G20 and non-OECD countries to participate in BEPS implementation on an equal footing.

The Inclusive Framework was officially established on 30 June 2016 at the founding meeting in Kyoto (29–30 June 2016); 82 countries joined. Membership grew rapidly to over 100 (2017), over 130 (2019), and over 140 jurisdictions (2021).

In July 2021, 130 of the then 139 members reached a high-level agreement on the Two-Pillar Solution. In October 2021, 137 of the by-then 141 members joined the final agreement; four countries — Kenya, Nigeria, Pakistan, and Sri Lanka — withheld consent. By 2023, membership had grown to over 145 jurisdictions.

In October 2023, the Inclusive Framework published the text of the Multilateral Convention (MLC) for Pillar One Amount A. Since 2024, negotiations to finalise and ratify the Pillar One Convention have continued. As of early 2025, the IF counts over 147 members.

The Inclusive Framework comprises all interested sovereign states and tax territories that commit to implementing the BEPS minimum standards. It functions as the primary international tax policy body alongside the UN Committee of Experts. Work is organised in thematic working groups producing recommendations, guidance, model legislation, and peer review reports. Decisions are taken by consensus; all members participate on an equal footing.

Since 2024, a parallel UN process exists in the form of an intergovernmental tax committee (based on UN General Assembly Resolution A/RES/78/230 of 2023), positioned as an alternative body to the OECD-led Inclusive Framework. This context is essential for understanding the evolving global tax architecture.

• Commitment to implementing the four BEPS minimum standards (Actions 5, 6, 13, 14)
• Participation in peer reviews of the minimum standards
• Contribution to ongoing BEPS work and voting processes
• Reporting implementation progress in the annual BEPS implementation report
• Engagement in thematic working groups
• Implementation of the agreed Two-Pillar Solution (Pillar 1 and Pillar 2)

4 corrections:
- Inconsistent member counts July vs October 2021 in the same entry
- effective_date imprecise: June 30, not June 1
- Founding meeting date wrong: June 30, not June 29
- Official URL returns HTTP 403 error
2 updates:
- Member count '145+' outdated, closer to 147-148
- Missing developments after July 2023 in history section
5 clarifications.
1 note.