The article evaluates the OECD BEPS Action Plan and recent progress in light of the key insights of the BEPS: (i) progress can be achieved solely through cooperation, and the existing competition based, unilateral action dominated paradigm is destined to fail; (ii) a comprehensive, holistic approach rather than ad hoc fix-ups is needed for a chance of success; and (iii) some innovations differing from the tradition that is the base for the current regime may be required in order to tackle the evolving new challenges that the regime faces. The article points to the promising aspects of the plan and to the areas where progress seem wanting. It further provides observations on certain steps that the OECD can and should take to increase the chances of success of the BEPS project.