OECD Releases Latest Peer Review Report on the Exchange of Information on Tax Rulings

On December 17, the OECD published the ninth peer review of the compulsory spontaneous exchange of information on tax rulings within BEPS Action 5 minimum standard (Transparency Framework). It covers activities of 139 jurisdictions in the sphere of tax information exchange, which joined BEPS Action 5 prior to June 30, 2024.

Key findings from the ninth peer report:

• As at 31 December 2024, over 28,500 tax rulings in scope of the transparency framework had been issued by the jurisdictions being reviewed. Over 2,300 tax rulings in scope of the transparency framework were issued in 2024 by the reviewed jurisdictions.

• Over 64,000 exchanges of information took place by December 31, 2024, with approximately 5,500 exchanges undertaken in 2024, 4,500 exchanges undertaken in 2023, 6,000 exchanges undertaken in 2022, 6,000 exchanges undertaken in 2021, 5,000 exchanges undertaken during 2020, 7,000 exchanges undertaken during 2019, 9,000 exchanges undertaken during 2018, 14,000 exchanges undertaken during 2017 and 7,000 exchanges during 2016.

• 113 jurisdictions did not receive any recommendations, as they have met all the terms of reference. 7 jurisdictions received only one recommendation.

• 46 recommendations for improvement have been made for the year in review.

• 94 peer input questionnaires were submitted providing feedback on the conduct of the exchanges by Inclusive Framework members. In some cases, selected jurisdictions were advised to revise their processes and improve the clarity and quality of information exchanged.

In a number of cases, the peer review process has assisted jurisdictions in identifying areas where improvement is required, and jurisdictions have been able to take action to implement changes over 2025 while the peer review was ongoing. Where these changes were implemented in 2025, they are generally not taken into account in the recommendations for the year 2024. However, these changes will be reviewed in a subsequent peer review.

OECD’s Harmful Tax Practices – 2024 Peer Review Reports on the Exchange of Information on Tax Rulings