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Tax Challenges Arising from Digitalisation – Economic Impact Assessment

Inclusive Framework on BEPS

image of Tax Challenges Arising from Digitalisation – Economic Impact Assessment

The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project laid the foundations of the project to address the tax challenges arising from the digitalisation of the economy with the release of the BEPS Action 1 Report. Since then, the OECD/G20 Inclusive Framework on BEPS has been working on the issue, delivering an interim report in March 2018, at the request of the G20.

In May 2019, the Inclusive Framework adopted a Programme of Work, which was endorsed by the G20 Finance Ministers and G20 Leaders in June 2019. The Programme of Work outlined proposals in two pillars that could form the basis for a multilateral consensus-based solution. It also provided that the OECD Secretariat would undertake an economic impact assessment of the proposals to ensure that all members of the Inclusive Framework could be kept fully informed of the economic and tax revenue impact of key decisions relating to the proposals.

This report presents an ex ante analysis of the economic and tax revenue implications of the Pillar One and Pillar Two proposals under discussion by the Inclusive Framework as part of its work to address the tax challenges arising from the digitalisation of the economy.

English Also available in: French

Investment Impacts of Pillar One and Pillar Two

The Pillar One and Pillar Two proposals would introduce significant changes to the international tax rules, affecting global investment through their impacts on the incentives faced by MNEs and governments. Amount A of Pillar One involves the creation of a new taxing right and the reallocation to market jurisdictions of a share of residual profit determined at the MNE group level, based on a formulaic approach. Pillar Two addresses remaining BEPS challenges and is designed to ensure that large internationally operating businesses pay a minimum level of tax regardless of where they are headquartered or the jurisdictions they operate in. Without prejudging the final design and parameter choices, which are still the subject of discussions among members of the Inclusive Framework on BEPS, the structural changes embedded in these new rules could have substantial direct and indirect effects on investment and economic output.

English Also available in: French

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