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Taxation of the Digital Economy and pushing fiscal boundaries


There is a widespread - but not yet universal - view that the international tax system needs reform in order to address the digitalisation of the global economy. 2018 and 2019 have seen both the OECD and the EU publish papers on this subject and the OECD has now released its proposals on allocating profit to different countries in which an international company makes sales or derives value. They are terming this the OECD ‘Unified Approach’, as it seeks to unify common components of proposals previously put forward (most notably by the US, the UK and India/Developing nations) with a view to seeking consensus to develop the detail of the Unified Approach in more detail.  

Pillar One: Taxation of the digital economy a ‘Unified Approach’

The Unified Approach would give countries the right to tax profits of international businesses (regardless of whether they have a base in the country or not) based on calculating up to three separate pots of profit. This moves away from the long established principle of “profit where the business has physical presence” which has been the cornerstone of the international framework, and represents arguably the most significant change in the international tax architecture in 100 years. 

Pillar Two: Global Anti-Base Erosion (GloBE) Proposals 

The Pillar Two proposals are designed to counter profit-shifting by multinationals who are subject to low or zero taxation. This is particularly an issue with intangibles but is also seen more broadly in entities that generate profits from intra-group financing. 

BDO’s latest insights 

Our direct interaction with the OECD during and since the formal consultation process, along with views gathered to date from global business through our ongoing survey continues to provide insights. 

Read the latest update following BDO’s interview on 3 December with Stewart Brant, head of Transfer Pricing at the OECD exploring key themes arising in particular from the Pillar 1 proposals, such as scope, threshold, avoiding double taxation, administration and timing.

BDO is undertaking worldwide research on unilateral measures being enacted at a local level and the impact on business and operating models. If you are interested in learning more sign up for "Taxation of the Digital Economy" here

You can view BDO’s submissions to the OECD here.

Leading Insights – recent highlights

BDO has been a leading commentator to the debate on the Taxation of the Digital Economy with our opinions featured extensively on the topic in Bloomberg Tax, Financial Times and more. 

  • BDO interviews the OECD: members of BDO's global Taxation of the Digital Economy Taskforce, were joined by Stewart Brant, head of Transfer Pricing at the OECD. Exploring key themes arising from the Pillar 1 proposals, such as scope, threshold, avoiding double taxation, administration and timing, we glean insights not yet in the public domain. 
  • Podcast: Tax Notes reporter Ryan Finely's summary of the OECD’s pillar 2 consultation draft and BDO’s Monika Loving provides her take on the proposal 
  • Read BDO International Tax Partner, Ross Robertson’s initial response to the OECD announcement of 9 October, and a leading article, recently published by Bloomberg Tax which explores the issues further
  • Robert Aziz, BDO Global Head of Tax, in an extract from a recent video interview below shares his perspective on What should a fair and workable global tax system look like in our modern global economy: