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ARTICLE · 29 OCTOBER 2021

OECD's Global Tax Reform 2021

Gardiner Roberts LLP
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In connection with the OECD's Base Erosion and Profit Shifting Project, a group of 140 countries have made commitments to radically modify the international tax system.

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Gardiner Roberts LLP
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In connection with the OECD's Base Erosion and Profit Shifting Project ("BEPS"), a  group of 140 countries have made commitments to radically modify the international tax  system.

Under BEPS Action 1, Pillar 1, it was agreed to adopt new profit allocation and nexus  rules so that 25% of large multinational enterprises' residual profits are redistributed to  the countries in which consumers are located. Market jurisdictions would then have a  taxing right over those residual profits. While this is a major shift away from the  requirement for a physical nexus to confer jurisdiction to tax, in today's digital world with  its absence of physical presence, there is a principled basis for shifting to a market based approach.

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