Base Erosion and Profit Shifting Project (BEPS Project) is an OECD/G20 project to set up an international framework to combat tax avoidance by multinational enterprises (“MNEs”) using base erosion and profit shifting tools. It refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no tax locations where there is little or no economic activity. It is of major significance for developing countries due to their heavy reliance on corporate income tax, particularly from multinational enterprises. India has ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, which was signed on 07/06/2017 on behalf of India.