Industry is aware of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (the Inclusive Framework) and the proposals for Addressing the Tax Challenges of the Digitalisation of the Economy.
The programme of work for the 135-member Inclusive Framework, as approved by the G20 Finance Ministers, provides for two pillars to be developed, with a consensus solution to be agreed by the end of 2020.
Pillar One addresses the allocation of taxing rights between jurisdictions and considers various proposals for new profit allocation and nexus rules.
Today (Friday, 8 November 2019) the Department for International Tax Cooperation informs industry that the OECD has invited public input on Pillar Two (also referred to as the “GloBE” proposal).
Pillar Two focuses on the remaining BEPS issues and seeks to develop rules that would provide jurisdictions with a right to “tax back,” where other jurisdictions have not exercised their primary taxing rights or the payment is otherwise subject to low levels of effective taxation.