OECD: Schedule for public consultations on two-pillar solution

Work on the implementation of the two-pillar plan is underway.

Two-pillar solution

The Organisation for Economic Cooperation and Development (OECD) today announced that work on the implementation of the two-pillar plan is underway following the October 2021 agreement reached by over 135 members of the OECD/G20 Inclusive Framework on BEPS to address the tax challenges arising from digitalisation and globalisation of the economy.

According to today’s OECD release, the Inclusive Framework intends to follow this schedule:

  • Amount A of Pillar One—Secretariat working documents will be released in the coming months on the separate building blocks of Amount A. This approach (rather than waiting for a comprehensive document to be ready) will allow work to continue in parallel and to remain within the political timetable agreed in October 2021.
  • Amount B of Pillar One—A public consultation document would be issued in mid-2022 with a public consultation event to follow the comment period.
  • Pillar Two—A public consultation on the implementation framework will be held in February 2022, with a focus on the particular issues to be agreed by the end of 2022 (i.e., administration and compliance).
  • Subject to tax rule” of Pillar Two—The draft model provision and its commentary will be released in March 2022 with a defined set of questions for input. The multilateral instrument to facilitate the implementation of the “subject to tax rule” would also be released for comment at the same time.

The release of this schedule follows yesterday’s publication by the OECD of model legislation to assist with the implementation of a reform to the international tax system—reform that is intended for multinational enterprises (MNEs) to be subject to a minimum 15% tax rate, effective from 2023. Read TaxNewsFlash


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