Subtle Shifts Seen in the OECD/Inclusive Framework’s Program of Work on Digitalization

    View Authors July 2019

    At a conference in Munich on June 28, 2019, remarks by key tax officials indicated that some of the lines in the OECD’s Program of Work on digitalization are being redrawn. In this article, published in Bloomberg Tax, Jeff VanderWolk, Tax Strategy & Benefits partner, analyzes these perceived shifts. In particular, the nexus test under Pillar One may be based on sales revenue alone; also, the definition of “consensus” among the 130 members of the Inclusive Framework will be more flexible than previously imagined; and, finally, the anti-base erosion rule of Pillar Two may apply to payments to unrelated parties.  Jeff advises that multinationals would be wise to monitor public statements of this kind, as the proposals appear to be evolving continuously.