Base Erosion and Profit Shifting Inclusive Framework

BEPS refers to planning strategies used by multinational enterprises to exploit gaps and mismatched in tax rules to avoid paying tax. The IF BEPS was established to combat BEPS and its negative effects ensuring interested countries and jurisdictions can participate on an equal footing in developing standards on BEPS related issues, and to also monitor the implementation of these standards via a peer review process.

There is a total of 15 Action Points that must be implemented but in Samoa’s case, priority is given to the 4 Minimum Standards:

    • Action 5: Countering Harmful Tax Practices more electing taking into account Transparency and Substance.
    • Action 6: Preventing the granting of Treaty Benefits in inappropriate circumstances.
    • Action 13: Improving tax transparency with Country by Country Reporting.
    • Action 14: Making Dispute Resolution Mechanisms More Timely, Effective and Efficient.

For general BEPS matters, contact the following authorized person:


Mr. Alesana Tumua

Authorized Competent

Authority Legal Consultant (International)

Legal & Technical Division

Ministry of Customs and Revenue


tel: +685 20411 ext.281