2 December 2019 Centre for Tax Policy and Administration Organisation for Economic Cooperation and Development 2 rue Andre-Pascal 75775 Paris Cedex 16 France By email to: taxpublicconsultation@oecd.org Introduction PwC International Ltd on behalf of its network of member firms (“PwC”) welcomes the opportunity to

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In a slide presentation for the OECD Steering Group of the Inclusive Framework circulated late Thursday, April 8th, the Biden Administration outlined its negotiating position on the OECD’s BEPS 2.0 project. The OECD’s project involves two “pillars”: Pillar 1 would create new income apportionment and nexus rules to allow jurisdictions to On 13 February 2020, the OECD hosted a webcast to discuss some of the preliminary results of its ongoing work on the economic analysis and impact assessment of the BEPS 2.0 project. 3 During that webcast, the OECD Secretariat noted that the analysis would be updated as the work on the BEPS 2.0 project progressed and further decisions were made by the Inclusive Framework on the specific COVID-19 pandemic and BEPS 2.0: a key area of focus in this assessment – the OECD Secretariat’s proposal for a unified approach under Pillar One of BEPS 2.0. OECD-Vorschlag zu Pillar 2 Am 08.11.2019 veröffentlichte die OECD das Konsultationspapier zum „Global Anti-Base Erosion Proposal“ (GloBE) als zweite Säule („Pillar 2“) der BEPS 2.0-Initiative „Addressing the Tax Challenges of the Digitalisation of the Economy“.

Notably the policy note discusses that there is agreement at the IF to examine two pillars. October 2020. With the recent release of the OECD blueprints for BEPS 2.0, the implementation of the proposed rules has the potential to undermine the 21 Jan 2020 The Pillar 2 consultation document suggests that consolidated financial statements could be used to determine the tax base for global income. Comments on Pillar I and Pillar II. Is the “Unified Approach” equal to BEPS 2.0 or a new way of allocating profits 14 Oct 2020 The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to On 12 October 2020, the G20/OECD Inclusive Framework on BEPS (“inclusive framework”) released two detailed “blueprints” in relation to its ongoing work to 10 Sep 2020 1. Background.

Contrary to expectations, there was no agreement on either blueprint by the Inclusive Framework members and it is now expected that consensus could be achieved by mid-2021. The OECD recently published the blueprints for Pillar One and Pillar Two of BEPS 2.0. The purpose of this Tax Insight is to provide some context and general commentary on the current state of BEPS 2.0, following the publication of the blueprints with a particular focus on how BEPS 2.0 interacts with the original policy behind BEPS 1.0 as well as other parts of the international tax system.

The Secretary also favours a Pillar 2 modelled on the US Global Intangible Low-Taxed Income (GILTI) framework, which would narrow the basis for any global consensus. The end of the last decade brought in significant tax changes with the OECD’s BEPS initiative that have been implemented broadly.

Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, the OECD has dedicated further resources and made significant progress on this topic as described by the 2019-12-02 January 2020: The OECD released a statement on the two-pillar approach to address the tax challenges arising from the digitalisation of the economy, announcing that the Inclusive Framework members had renewed their commitment to the BEPS 2.0 project and providing a revised pillar one PoW and an update on pillar two, which was also endorsed by the G20. 2020-11-16 With respect to Pillar Two, the Report suggests that the global revenue gains from the proposal could be significant, representing the bulk of the potential gains from the BEPS 2.0 project. The Report notes that the impact of Pillar Two would fall on MNEs with low-taxed … BEPS 2.0: Pillar Two and Insurers. In late 2020, the OECD released a set of work-in-progress proposals aimed at reforming the international tax system. They were intended to address taxation challenges arising from the digitalisation of the economy and remaining concerns around base erosion and … These reports, referred to as “blueprints”, address what have come to be known as Pillar One and Pillar Two of BEPS 2.0.

On 13 February 2020, the OECD hosted a webcast to discuss some of the preliminary results of its ongoing work on the economic analysis and impact assessment of the BEPS 2.0 project. 3 During that webcast, the OECD Secretariat noted that the analysis would be updated as the work on the BEPS 2.0 project progressed and further decisions were made by the Inclusive Framework on the specific

Dec 2020. publication. The matter of directly addressing the tax challenges of the digitalised economy was effectively parked in the course of the OECD’s base erosion and profit shifting (BEPS) project. READ MORE The Pillar One and Two blueprints (BEPS 2.0) following a meeting of the OECD-led coalition of 137 countries, were released yesterday. Contrary to expectations, there was no agreement on either blueprint by the Inclusive Framework members and it is now expected that consensus could be achieved by mid-2021. Highlights: The top priority of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has been to develop a solution to the tax challenges of the digitalisation of the economy. On 12 October 2020, the Inclusive Framework released a package consisting of the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint .

On 8 November 2019, the Organisation for Economic Co-operation and Development (OECD) released a public consultation document on the Global Anti-Base Erosion (GloBE) proposal under Pillar Two of the ongoing project titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (the Consultation Document). • Pillar Two is the “GloBE” proposal involving the development of a coordinated set of rules to address ongoing risks from structures that are deemed to allow multinational enterprises to shift profit to jurisdictions where they are subject to no or very low taxation.
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Pillar Two focuses on the remaining BEPS issues and seeks to develop rules that introduce the concept of a global minimum rate of tax.

Summary: The Pillar One and Two blueprints (BEPS 2.0) following a meeting of the OECD-led coalition of 137 countries, were released yesterday. Contrary to expectations, there was no agreement on either blueprint by the Inclusive Framework members and it is now expected that consensus could be achieved by mid-2021.
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COVID-19 pandemic and BEPS 2.0: a key area of focus in this assessment – the OECD Secretariat’s proposal for a unified approach under Pillar One of BEPS 2.0.

In summary, Pillar One focuses on the allocation of taxing rights. Pillar Two focuses on the remaining BEPS issues and seeks to develop rules that introduce the concept of a global minimum rate of tax.