BEPS 2.0: Pillar One and Pillar Two On 12 October 2020, the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) released ‘blueprints’ on Pillar One and Pillar Two, which reflect the efforts made towards reaching a multilateral, consensus-based solution to the tax challenges arising from the digitalization of the economy.

See EY Global Tax Alert, BEPS 2.0 – Pillar Two: the OECD issues consultation document on design of global minimum tax rules, dated 8 November 2019. See EY Global Tax Alert, OECD hosts public consultation on global anti-base erosion (GloBE) proposal under Pillar Two of BEPS 2.0 project, dated 13 December 2019.

The BEPS 2.0 Pillar 1 and Pillar 2 Blueprints have been released by the OECD’s Inclusive Framework and are now open for public consultation BEPS 2.0 – Pillar one and Pillar two blueprints - KPMG United Kingdom Pillar One: Profit Allocation and Nexus. Further reading & resources. KPMG report Pillar One KPMG report taxation of the digitalized economy KPMG in the UK digitalized economy portal page KPMG BEPS 2.0 Model. The Unified Approach — Pillar One is a set of proposals to revisit tax allocation rules in a changed economy. 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 undertaken by the Inclusive Framework under BEPS 2.0, OECD documents on BEPS 2.0 include new details and identify issues under consideration on Pillar One and Pillar Two Executive summary On 31 January 2020, the Organisation for Economic Co-operation and Development (OECD) released a Statement by the Inclusive Framework on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalization of the Economy (the Statement ). On 12 October 2020, the OECD and the OECD/G20 Inclusive Framework on BEPS released a series of documents in connection with the BEPS 2.0 project, including a detailed report on the Blueprint on Pillar One (the Blueprint).10 The Pillar One Blueprint 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 1

There is 1. See EY Global Tax Alert, The OECD takes next step on BEPS 2.0 – Proposal for a “unified approach” for additional market country tax, dated 10 October 2019. 2. See EY Global Tax Alert, OECD hosts public consultation on proposed “unified approach” under Pillar One of BEPS 2.0 project, dated 27 November 2019. 3. 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 Addressing the tax challenges raised by digitalisation has been a top priority of the OECD/G20 Inclusive Framework in BEPS since 2015 with the release of the BEPS Action 1 Report. At the request of the G20, the Inclusive Framework has continued to work on the issue, delivering an interim report in March 2018.

1. See EY Global Tax Alert, The OECD takes next step on BEPS 2.0 – Proposal for a “unified approach” for additional market country tax, dated 10 October 2019. 2.

BEPS 2.0 Update: Een nieuw belastingstelsel voor een digitale tijd 25 februari 2020 Op 9 oktober jl. werd een consultatiedocument door de Organisatie voor Economische Samenwerking en Ontwikkeling (OESO) gepubliceerd met een beschrijving van hoe een wereldwijde oplossing op basis van de eerste pijler (Pillar 1) eruit kan zien.

OECD:s “Pillar 1” och “Pillar 2” - nu är rapporterna publicerade. För att uppnå samstämmighet, substans och transparens på skatteområdet och Development team, Autoliv was one of around 20 organiza- area and A-pillars.

OECD releases BEPS 2.0 Pillar Two Blueprint and invites public comments Executive summary On 12 October 2020, the Organisation for Economic Co-operation and Development (OECD) released a series of major documents in connection with the ongoing G20/OECD project titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (the BEPS 2.0 project).

Directed at re-allocating taxing rights to the jurisdiction where the end-user is located. on the Pillar One framework must be achieved by the January meeting. 27 November 2019 Global Tax Alert OECD hosts public consultation on proposed “unified approach” under Pillar One of BEPS 2.0 project EY Tax News Update: Global Edition EY’s Tax News Update: Global Edition is a free, personalized email subscription service that allows 2020-10-26 Introduction. On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released the Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalisation of the Economy – January 2020 (January Statement) outlining what is currently the agreed upon “architecture” or “outline” of Pillar One and Pillar Two. International Tax Update: U.S. Outlines Position on OECD BEPS 2.0 Project April 9, 2021, Covington Alert In a slide presentation for the OECD Steering Group of the Inclusive Framework circulated late Thursday, April 8th, the Biden Administration outlined its negotiating position on the OECD’s BEPS 2.0 project. OECD releases BEPS 2.0 Pillar Two Blueprint and invites public comments Executive summary On 12 October 2020, the Organisation for Economic Co-operation and Development (OECD) released a series of major documents in connection with the ongoing G20/OECD project titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (the BEPS 2.0 project). 2020-07-24 BEPS 2.0.

Unsubscribe. En gång i månaden. The Ernst & Young BEPS 2.0: Pillar One and Pillar Two On 12 October 2020, the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) released ‘blueprints’ on Pillar One and Pillar Two, which reflect the efforts made towards reaching a multilateral, consensus-based solution to the tax challenges arising from the digitalization of the economy. The BEPS 2.0 Pillar 1 and Pillar 2 Blueprints have been released by the OECD’s Inclusive Framework and are now open for public consultation BEPS 2.0 – Pillar one and Pillar two blueprints - KPMG United Kingdom Pillar One: Profit Allocation and Nexus. Further reading & resources.
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Pillar 1 of BEPS 2.0 is made up of two parts. One part, Amount A allocates a portion of deemed residual profits of certain in-scope multinational enterprises (MNE) to market jurisdictions.

Despite the United States’ reluctance to support Pillar 1 and the widely diverging views of different nations, there is still strong political pressure to progress. 1.
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1. In light of the strong support from the Inclusive Framework on BEPS (IF) members for reaching a multilateral agreement with respect to Pillar One and Pillar Two, and drawing on the technical work of the Working Parties, comments from the public consultation, as well as the discussion at a number of Steering

Contrary to expectations, there was no agreement on either blueprint by the Inclusive Framework members and it is now expected that consensus could be … 2020-10-13 1. In light of the strong support from the Inclusive Framework on BEPS (IF) members for reaching a multilateral agreement with respect to Pillar One and Pillar Two, and drawing on the technical work of the Working Parties, comments from the public consultation, … 2020-10-15 2021-03-03 In October 2019, the OECD released proposals for a new unified approach to taxation of multinational enterprises in the digital environment, the so-called Pillar 1 of the BEPS 2.0 project. In November 2019, the OECD also released the Global Anti-base Erosion (GloBE) proposal, the so-called Pillar 2 of the BEPS 2.0 project. On 12 October 2020, the G20/OECD Inclusive Framework on BEPS Further details of Pillar One were expected to be released in January 2020.

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Development team, Autoliv was one of around 20 organiza- area and A-pillars. tion to average capital employed, declined to 2.0 times, profit shifting (“BEPS”) project begun in 2015 with new proposals for a global

Pillar Two focuses on the digitaliserad och globaliserad ekonomi: BEPS 2.0 (2019/2901(RSP)) a “Unified Approach” under Pillar One och Global Anti-Base Erosion Den 12 oktober 2020 publicerade OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), så kallade “blueprints”, för Pillar av de förändringar som OECD planerar med BEPS 2.0 om den digitala Anti-Base Erosion (GloBE) Proposal under Pillar Two (PDF 714 KB). by TCJA provisions – OECD BEPS 2.0 Pillar 1 and Pillar 2 comment period ends; BIAC calls for limited BEPS agreement by June 2021 – among other topics.