As part of the Base Erosion and Profit Shifting (BEPS) project launched in 2013, the Organisation for Economic Co-operation and Development (OECD) specifically raised concerns about preferential tax treatment of income generated by intellectual property and recommended that these regimes require from the beneficiaries to conduct real economic activities to prevent them from being identified as harmful tax practices. The adoption by several countries of intellectual property regimes in line with the OECD’s recommendation illustrates the substitution effect between forms of tax competition and increases the pressure on other forms of tax competition.