In 2013, the OECD/G20 launched the Base Erosion and Profit Shifting (BEPS) project to deal with the issue of corporate tax avoidance. In 2015, BEPS 1.0 culminated with the release of a series of action items that the OECD/G20 countries have committed to adopt. BEPS 1.0 represents the first substantial renovation of the international tax regime (ITR) in almost a century, but it is still inadequate. The basic problem is that BEPS 1.0 takes as a given the fundamental consensus underlying the ITR, the Benefits Principle, where active income is taxed primarily at source while passive income is taxed primarily at residence. This compromise between the claims of residence and source countries is embedded in over 3,000 bilateral tax treaties and in the domestic laws of the United States and most other countries. Not surprisingly, it is also reflected in BEPS 1.0, which, in part, is an attempt to improve source-based taxation of active income. This old consensus should be reconsidered. The shortcomings of BEPS 1.0 are directly related to its reliance on the benefits principle, because upholding it requires cooperation by too many jurisdictions, showing the need for the reforms of BEPS 2.0.