In the evolving landscape of international taxation, the
Organization for Economic Co-operation and Development (OECD) has
introduced two significant frameworks: Pillar One and Pillar Two.
These frameworks aim to address the challenges posed by the
digitalization of the economy and base erosion and profit shifting
(BEPS) practices by multinational enterprises (MNEs). Their
implementation poses both challenges and opportunities for
jurisdictions like Egypt, particularly concerning the application
of domestic income tax laws and existing double tax
treaties.
Pillar Two: Ensuring a Minimum Level of Taxation for MNEs
Pillar Two aims to ensure that large MNEs pay a minimum level of
tax on the income arising in each jurisdiction where they operate.
This global minimum tax is intended to address remaining BEPS
issues, such as profit shifting to low-tax jurisdictions and the
use of aggressive tax planning strategies to minimize tax
liabilities.
