Base erosion and profit shifting


Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint

Inclusive Framework on BEPS

The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. Addressing the tax challenges raised by digitalisation has been a top priority of the OECD/G20 Inclusive Framework in BEPS since 2015 with the release of the BEPS Action 1 Report. At the request of the G20, the Inclusive Framework has continued to work on the issue, delivering an interim report in March 2018. In 2019, members of the Inclusive Framework agreed to examine proposals in two pillars which could form the basis for a consensus solution to the tax challenges arising from digitalisation. That same year, a programme of work to be conducted on Pillar One and Pillar Two was adopted and later endorsed by the G20. This report explores options and issues in connection with the design of a global minimum tax that would address remaining BEPS issues.

Published on October 14, 2020Also available in: French

In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles


Abbreviations and acronyms
Cover Statement by the OECD/G20 Inclusive Framework on BEPS on the Reports on the Blueprints of Pillar One and Pillar Two
Executive Summary
Scope of the GloBE rules
Calculating the ETR under the GloBE rules
Carry-forwards and carve-out
Simplification options
Income Inclusion and Switch-Over Rules
Undertaxed Payments Rule
Special rules for Associates, joint ventures and orphan entities
Subject to tax rule
Implementation and Rule Co-ordination
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