A Whole New Ballgame: The Global Tax Policy Negotiations on Pillars One and Two

    View Author May 2021

    The OECD/G20 Inclusive Framework’s two-pillar project on the tax challenges of digitalization, sometimes called BEPS 2.0, has been ongoing for more than two years. Originally aimed at updating international tax rules to ensure that taxes could be imposed in market countries on nonresident sellers of digitalized services and products, the project quickly underwent ‘‘mission creep’’ and grew to encompass broader proposals to reallocate to market countries above-normal profits of consumer-facing businesses, clarify the taxation of cross-border marketing and distribution activities, and implement a global minimum tax regime common to all countries.

    *This article was first published in Bloomberg Tax on May 13, 2021.