OECD: Outcome statement on BEPS 2.0

The statement summarizes the package of deliverables developed by the Inclusive Framework to address remaining elements of Two‐Pillar Solution

Outcome statement on BEPS 2.0

The Organisation for Economic Cooperation and Development (OECD) today released an Outcome Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy [PDF 165 KB], describing the progress made by 138 members of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) on implementation of major reform of the international tax system.

As explained by today’s OECD release, the outcome statement agreed at the 15th Meeting of the Inclusive Framework follows 20 months of intense technical negotiations by delegates to continue the work to implement the Two-Pillar Solution. The statement summarizes the package of deliverables developed by the Inclusive Framework to address the remaining elements of the Two‐Pillar Solution:

  • Text of a multilateral convention (MLC), which allows jurisdictions to reallocate and exercise a domestic taxing right over a portion of the residual profits of multinational enterprises (Amount A of Pillar One).
    • The Inclusive Framework will publish the text of the MLC once it has been prepared for signature, upon resolution of a small number of specific items, as a few jurisdictions have expressed concerns with some specific items in the MLC.
  • Proposed framework for the simplified and streamlined application of the arm’s length principle to in-country baseline marketing and distribution activities (Amount B of Pillar One).
    • Input from stakeholders is requested on certain aspects prior to finalization.
  • Subject-to-tax rule (STTR) together with its implementation framework, which will enable developing countries to update bilateral tax treaties to “tax back” income on certain intra-group income where such income is subject to low or nominal taxation in the other jurisdiction.
  • Comprehensive action plan will be prepared by the OECD to support the swift and coordinated implementation of the Two-Pillar Solution, coordinating with regional and international organizations.

In addition, the members of the Inclusive Framework agreed in the outcome statement to refrain from imposing newly enacted digital services taxes or relevant similar measures on any company before 31 December 2024, or the entry into force of the MLC if earlier, provided the signature of the MLC has made sufficient progress by the end of the year.

Next steps

  • The outcome statement will be delivered to G20 Finance Ministers and Central Bank Governors at their meeting in Gandhinagar, India on 17-18 July 2023.
  • Technical work will continue so that the MLC can be opened for signature in the second half of 2023, with a signing ceremony by year-end. The MLC should enter into force during 2025, allowing for the domestic consultation, legislative, and administrative processes applicable in each jurisdiction.
  • Further work on Amount B of Pillar One, to be launched next week with a public consultation through 1 September 2023, is slated for completion by year-end. The Inclusive Framework plans to approve a final report on Amount B and incorporate key content into the OECD Transfer Pricing Guidelines by January 2024. Due consideration will be given to the needs of low-capacity jurisdictions and the interdependence with the MLC.
  • The agreed documentation relating to the STTR will be published next week, with the multilateral instrument implementing the STTR to be released and open for signature from 2 October 2023.
  • The OECD will also prepare a comprehensive action plan to support the swift and coordinated implementation, with additional support and technical assistance to enhance capacity for implementation by developing countries.


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