OECD revises BEPS Action 5 transparency framework to enhance tax ruling exchanges, update peer review processes, and introduce a new XML schema for implementation from 2027

The report on the BEPS Action 5 transparency framework sets out revisions to strengthen the spontaneous exchange of information on tax rulings, including updated terms of reference effective from the 2025 review cycle and a revised peer review methodology to be applied from 2026. It also introduces a revised Exchange on Tax Rulings (ETR) XML Schema and User Guide, which will apply to all exchanges from 1 January 2027.