OECD: Pillar One and Pillar Two “Blueprints” and tax challenges of digital economy (text of reports)

OECD: Pillar One and Pillar Two “blueprints”

The Organisation for Economic Cooperation and Development (OECD) this morning officially released reports described as “Blueprints” concerning solutions to the tax challenges arising from digitalisation of the economy.


These reports reflect efforts for reaching a multilateral, consensus-based solution to the tax challenges arising from the digitalisation of the economy, and other tax deliverables, and will be reported by the OECD Secretary-General to the G20 Finance Ministers. Read today’s OECD statement [PDF 304 KB].

  • The OECD report of the Pillar One Blueprint [PDF 4.8 MB] (232 pages) reflects a focus on new nexus and profit allocation rules so that, in an increasingly digital age, the allocation of taxing rights with respect to business profits is no longer exclusively circumscribed by reference to physical presence.
  • The OECD report of the Pillar Two Blueprint [PDF 4.3 MB] (248 pages) reflects an approach that is focused on the remaining base erosion and profit shifting (BEPS) challenges and proposes a systematic solution designed so that all internationally operating businesses pay a minimum level of tax. Pillar Two leaves jurisdictions free to determine their own tax system, including whether they have a corporate income tax and where they set their tax rates, but also considers the right of other jurisdictions to apply the rules contained in this report where income is taxed at an effective rate below a minimum rate.

The purpose of this edition of TaxNewsFlash is to provide text of the two OECD reports.

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