Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint
Inclusive Framework on BEPS
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The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. Addressing the tax challenges raised by digitalisation has been a top priority of the OECD/G20 Inclusive Framework in BEPS since 2015 with the release of the BEPS Action 1 Report. At the request of the G20, the Inclusive Framework has continued to work on the issue, delivering an interim report in March 2018. In 2019, members of the Inclusive Framework agreed to examine proposals in two pillars which could form the basis for a consensus solution to the tax challenges arising from digitalisation. That same year, a programme of work to be conducted on Pillar One and Pillar Two was adopted and later endorsed by the G20.
This report explores options and issues in connection with the design of a global minimum tax that would address remaining BEPS issues.
Also available in: French
Calculating the ETR under the GloBE rules
This chapter sets out the rules for determining an MNE’s effective tax rate (ETR) under the GloBErules. The Globe ETR is determined by dividing the amount of covered taxes by the amount of income as determined under the GloBErules. Section below sets out the definition of covered taxes and Section describes the methodology for calculating an MNE’s income for GloBE purposes. As described in further detail in Section , the GloBErules start with the financial accounts that are prepared under the same accounting standard that is used by the parent of the MNE to prepare its consolidated financial statements. The rules then require certain adjustments to be made to those financial accounts to eliminate specific items of income from the tax base, such as intra-group dividends, and to incorporate certain expenses, such as tax deductible stock-based compensation. Section also describes a number of modifications that can be made to the tax base to address differences in the timing in the recognition of income and taxes. The first modification, described in Section , addresses timing issues that can arise through immediate expensing and accelerated depreciation of assets for local law purposes. The second modification, described in Section , addresses the timing issues raised by distribution-based corporate income tax systems. Finally, Section describes an exclusion from the GloBE tax base for emergency government assistance.
Also available in: French
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