The international tax landscape for some multinational
enterprises (MNEs) is changing — probably. But many details
remain to be worked out and political uncertainty (particularly in
the United States) still must be navigated for a deal that aims to
raise approximately US$150 billion a year from MNEs and reallocate
some additional taxing rights to market jurisdictions.
The OECD and G20 have been working for the past two years on a
two-pillar approach to international tax reform to address the
taxation of the digital economy and unresolved BEPS issues. On
October 8, 2021, 136 countries of the OECD/G20 Inclusive Framework
announced that they have agreed to this two-pillar
solution [PDF] (the Statement). The Statement largely confirms
the elements laid out in their July 1, 2021, statement, with some
added details, but there is still significant further detail to
come. For a discussion on the July 1, 2021, statement,
see our Osler Update and our submission to the OECD [PDF
