The BEPS Action Plan is an internationally coordinated project headed by the OECD designed to address the problem of base erosion and profit shifting in which multinational enterprises are allowed to shift their profits to low or no-tax jurisdictions, thereby eroding the tax base of many others. The BEPS Action Plan is based on three core principles: coherence, substance and transparency, and sets forth 15 actions to fundamentally change the rules for the taxation of cross-border profits.