Sandy Bhogal and James Chandler (Gibson, Dunn & Crutcher) review the proposed reforms allocating corporate profits to customer-heavy jurisdictions and imposing a global minimum tax rate.
How did we get here?
To understand the genesis of the OECD’s statement on 1 July 2021 you have to cast your mind back to BEPS Action 1 on addressing the tax challenges of a digital economy. The final report on Action 1 (back in 2015) effectively told us that the digital economy exacerbated existing international tax headaches but could not be siloed into a separate regime. In 2018 an interim report on Action 1 confirmed that more work would be undertaken to review how the concepts of the international tax system were impacted by the digital economy and to achieve a consensus on a multilateral approach (and thus we had BEPS 2.0). After some consultation in 2019 and various publications throughout...
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Sandy Bhogal and James Chandler (Gibson, Dunn & Crutcher) review the proposed reforms allocating corporate profits to customer-heavy jurisdictions and imposing a global minimum tax rate.
How did we get here?
To understand the genesis of the OECD’s statement on 1 July 2021 you have to cast your mind back to BEPS Action 1 on addressing the tax challenges of a digital economy. The final report on Action 1 (back in 2015) effectively told us that the digital economy exacerbated existing international tax headaches but could not be siloed into a separate regime. In 2018 an interim report on Action 1 confirmed that more work would be undertaken to review how the concepts of the international tax system were impacted by the digital economy and to achieve a consensus on a multilateral approach (and thus we had BEPS 2.0). After some consultation in 2019 and various publications throughout...
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:
