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As part of the work to develop a solution to the tax challenges of the digitalisation of the economy, the Organisation for Economic Co-operation and Development (OECD)/G20 inclusive framework on base erosion and profit sharing (BEPS) has published blueprints on BEPS 2.0 pillar one and pillar two.
The documents reflect the convergent views on many of the policy features, principles and parameters of both pillars.
The documents acknowledge that political consensus must still be reached on several areas. The OECD invites comments on the blueprints, in particular in relation to:
- the scope of pillar one;
- the inclusion of safe harbours and thresholds;
- the appropriate dispute resolution mechanism for pillar one; and
- whether groups subject to the US global intangible low taxed income regime rules should be excluded from pillar two.
Responses should be emailed to cfa@oecd.org by 14 December 2020.
