The BEPS report, previously released, and the new Action Plan are available for public review, with many commentators already providing insight on the Action Plan.
The 24 month Action Plan is comprehensive and aggressive, with tax transparency and disclosure rules likely to be implemented early in that timeline. The report also discusses an improvement of global rules in developing countries, further referenced by work of the Tax Inspectors without Borders study, as discussed in my 9 June 2013 post.
One very interesting proposal in the report is the development of a multilateral convention to address BEPS issues. This will allow countries to rapidly implement some actions without formally renegotiating bilateral treaties. Additionally, Appendix C provides examples of tax planning structures by multinational organizations.
The OECD BEPS report and Action Plan will provide additional momentum and debate for the proposed actions, for which multinationals should prepare an internal action plan to address such initiatives.