BEPS Two-Pillar Solution: Where Are We Now?

In October 2021, a significant number of member jurisdictions of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) came together to reform global tax rules through a Two-Pillar solution. These reforms, often called BEPS 2.0, seek to tackle the tax challenges arising from the digitalisation of the economy, ensuring that multinational enterprises (MNEs) pay a fair share of taxes where they operate. The first Pillar gives taxing rights over MNEs’ profits to countries where the final users are through Amount A, while Pillar Two introduces a global minimum tax of 15% on MNEs’ profits.

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