Against a proliferation of unilateral measures worldwide aimed at the digital economy, the OECD seeks international consensus to implement a radical new proposal that will reallocate (and perhaps enlarge) the tax pie between nations. ‘Pillar 1’ of the OECD’s proposals would transform the tax pie into two-tier gateau (routine profit beneath and residual profit on top); whereas, BEPS revisited (aka ‘pillar 2’) looks to introduce some form of super controlled foreign company rule to stop profit diversion, and a race-to-the-bottom dropping of tax rates by local tax authorities. But pillars 1 and 2 do not just involve digital companies, but all MNEs that face consumers.
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Against a proliferation of unilateral measures worldwide aimed at the digital economy, the OECD seeks international consensus to implement a radical new proposal that will reallocate (and perhaps enlarge) the tax pie between nations. ‘Pillar 1’ of the OECD’s proposals would transform the tax pie into two-tier gateau (routine profit beneath and residual profit on top); whereas, BEPS revisited (aka ‘pillar 2’) looks to introduce some form of super controlled foreign company rule to stop profit diversion, and a race-to-the-bottom dropping of tax rates by local tax authorities. But pillars 1 and 2 do not just involve digital companies, but all MNEs that face consumers.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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