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Going GloBal: the OECD’s consultation on pillar two

Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.

The story so far

In January 2019 the Inclusive Framework issued a policy note on Addressing the tax challenges of the digitalisation of the economy under which they proposed that the issues should be addressed under two pillars. Pillar one looks to a new allocation of taxing rights through new nexus and profit allocation rules and the OECD consultation on this was published on 9 October 2019 together with an OECD Secretariat proposal for a unified approach (as to which see our previous article). The period for comments on this closed on 12 November with a public consultation to be held on 21 and 22 November so there may well be more on this soon.

Pillar two also known as the...

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