There has been essentially no growth in the profits US firms report in the world's major markets (apart from the UK) over the last twenty years. All the growth in profits has been in a small number of low tax jurisdictions
The tax rate on these profits now? Just over 10.5%
the OECD's BEPS process on its own isn't going to solve the problem of profit shifting; there are too many new BEPS compliant tax structures springing up.