The Action plan consists of 15 measures to strengthen corporate income tax rules and prevent tax avoidance through manipulating intra-group transfer pricing between subsidiaries, and the use of empty shell companies in low tax jurisdictions.
Tax challenges created by globalised production and service systems, the digital economy and increasing importance of "intangibles" – research & development, intellectual property – features prominently in the OECD Action plan. The OECD action plan was mandated by the G20 finance ministers and is to be endorsed by the G20 Meeting in St. Petersburg in September 2013.