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OECD: Plan for resolving tax challenges of digital economy

Plan for resolving tax challenges of digital economy

The Organisation for Economic Cooperation and Development (OECD) today reported that there is an agreement for a “road map” with regard to resolving the tax challenges arising from the digitalization of the economy and a commitment for continued work toward a consensus-based long-term solution by the end of 2020.

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The OECD release states that 129 members of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) have adopted a plan—a “Programme of Work” [PDF 3.76 MB]—that sets out a process for reaching a new global agreement for taxing multinational enterprises.

The plan (adopted at the 28-29 May 2019 meeting of the Inclusive Framework members) calls for intensifying international discussions around two main pillars, and will be presented to the G20 finance ministers for endorsement during their 8-9 June 2019 in Fukuoka, Japan.

The plan explores technical issues to be resolved through the two main pillars.

  • The first pillar will consider potential solutions for determining where tax is to be paid and on what basis ("nexus"), as well as what portion of profits could or should be taxed in the jurisdictions where clients or users are located ("profit allocation").
  • The second pillar will explore the design of a system to determine that multinational enterprises (included in the digital economy) pay a minimum level of tax. This pillar would provide countries with a new tool to protect their tax base from profit shifting to low or no-tax jurisdictions, and is intended to address remaining issues identified in the BEPS initiative.

The Inclusive Framework agreed that the technical work must be complemented by an assessment as to how the proposals will affect government revenue, growth, and investment—and there are political considerations for reaching a comprehensive and unified solution “ideally before year-end” to allow for completion of the work during 2020.

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