Pillar One’s Reallocation of Taxing Rights: Has Anyone Consulted the U.S. Trade Representative?

    View Author July 2021

    The global tax policy process undertaken by the OECD/G20 Inclusive Framework on BEPS took a big step forward on July 1, 2021, when the group issued a statement, to which 130 of the 139 members subscribed, outlining the revised features of the Pillar One and Pillar Two plans that have been in development for the past two-and-a-half years. Two additional members have since signed up, bringing the total number in support to 132 jurisdictions. The seven remaining holdouts—Ireland, Hungary, Estonia, Kenya, Barbados, Nigeria, and Sri Lanka—are not political or economic giants, but three of them are EU member states, which creates a question as to the ability of the EU to implement the agreed proposals in due course.

    *This article was first published in Bloomberg Tax on July 14, 2021.