The fourth and final part of this series (albeit not the end of BEPS 2.0) considers the responses of different jurisdictions to the proposals under Pillar One and Pillar Two. EU response. Simultaneously with the work of the Inclusive Framework, the European Commission has also considered the taxation of the digital economy.

Further announcements in respect of BEPS 2.0 are now expected in October 2020. In anticipation of these developments, it is worthwhile to recap on the BEPS Project to date. This four-part series will look back at how BEPS 2.0 came about, discuss the Pillar One and Pillar Two proposals announced under BEPS 2.0, and consider the responses of various jurisdictions.

Establishments. 2.0 at the of the matter 10 Mar 2019 The designations employed and the presentation of material on any map in countries that are not OECD members (Bulgaria, Croatia, Cyprus, Lithuania, 2.0. 2.5. Taiwan. Province of China.

05 February, 2021. In late 2020, the OECD released a set of work-in-progress proposals aimed at reforming the international tax system. They were intended to address taxation challenges arising from the digitalisation of the economy and remaining concerns around base erosion and profit shifting (BEPS). Be ready for BEPS 2.0.

Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, the OECD has dedicated further resources and made significant progress on this topic as described by the OECD in their "Update on the Programme of Work since February 2020", included in the OECD’s Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors report published in

BEPS 2.0, as currently contemplated, clearly goes beyond and is inconsistent with the DEMPE and control of risk rules. This does not mean that DEMPE and the BEPS risk rules are irrelevant: Pillar One would leave room for them with respect to the allocation of routine profits attributable to marketing intangibles, as well as some portion of non-routine profits. 2020-10-26 OECD BEPS 2.0 measures. The OECD is considering measures to address these issues under two pillars, Pillar One and Pillar Two. Pillar One is this idea of expanding taxing rights or changing taxing rights based on some expanded nexus idea so that, for example, Please contact any member of our BEPS 2.0 Team if you would like to discuss how these changes may affect your business.

Further announcements in respect of BEPS 2.0 are now expected in October 2020. In anticipation of these developments, it is worthwhile to recap on the BEPS Project to date. This four-part series will look back at how BEPS 2.0 came about, discuss the Pillar One and Pillar Two proposals announced under BEPS 2.0, and consider the responses of various jurisdictions.

BEPS 2.0 Tax challenges arising from the digitalisation of the economy Prepared for the next phase of BEPS? The OECD’s Base Erosion and Profit Shifting Project (BEPS) aims to secure and sustain the international tax system and increase tax equity among traditional and digital businesses. Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, the OECD has dedicated further resources and made significant progress on this topic as described by the OECD in their "Update on the Programme of Work since February 2020", included in the OECD’s Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors report published in July 2020. BEPS 2.0 - Part 2: Pillar One Cadwalader Wickersham & Taft LLP OECD July 23 2020 The first part in this series looked at the OECD’s work in relation to BEPS 1.0 and introduced the subsequent work The new documents on the BEPS 2.0 project published by the OECD on 12 October 2020 include the following: Cover Statement by the OECD/G20 Inclusive Framework on BEPS on the Reports on the Blueprints of Pillar One and Pillar Two Inclusive Framework Report on the Pillar One Blueprint Inclusive Framework Report on the Pillar Two Blueprint provided an update on developments in the BEPS 2.0 project during an online press conference. In addition, the OECD Secretariat hosted a webcast to provide a more technical update on progress on the BEPS 2.0 project and its other international tax work.

4 Dec 2016 the development of the global tax policy norms that led to BEPS, the OECD invited certainly be a BEPS 2.0 and beyond. A still-unanswered 18 Aug 2020 The PPT disallows a treaty benefit where obtaining the benefit was one [1] OECD, 94 “Signatories and Parties to the Multilateral Convention 11 Oct 2019 around these issues (eg, MAAL, DPT, treaty PPT) with more in prospect under BEPS 2.0 means that the need for complex corporate residence steuerrechtsordnung: Pillar 1 & 2 (BEPS 2.0). • Ausweitung und LoB/PPT,. LoB. BEPS: Minimum Standard. BEPS: No Minimum Standard.
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From these, resulted Vienna convention, the model tax convention by Organization for Economic Cooperation and Development (OECD) and the BEPS 2.0 — Part 2: Pillar One. The first part in this series looked at the OECD’s work in relation to BEPS 1.0 and introduced the subsequent work undertaken by the Inclusive Framework under BEPS 2.0, specifically the Pillar One and Pillar Two proposals. BEPS 2.0 (Pillar 2) - How will the anticipated overhaul of international tax rules impact on aircraft leasing? December 2020 Following the release of our first newsletter on the topic, check out our latest thoughts on the possible impact of the BEPS 2.0 (pillar two) proposed rules on specific aircraft leasing platform jurisdictions and structures. 2020-11-02 “BEPS 2.0” describes the continuation of work in this space. Further announcements in respect of BEPS 2.0 are now expected in October 2020.

Andrew Auerbach, Senior Tax Adviser. Centre for Tax Policy and Administration. OECD Jakarta Office. Background.
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The U.S. LOB rules are currently undergoing a public consultation and the OECD will await its outcome in considering its impact on Action 6. The PPT is similar in.

A replay of the webcast and the presentation slides can be accessed on the OECD website. OECD’s Work Program for BEPS 2.0 Key Findings • The OECD is continuing its work to develop proposals that could change international taxation rules.

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2020-10-26

Background. 2015.