The Organization for Economic Cooperation and Development (OECD)
has been executing on its initiative to address perceived
exploitation of the global taxation system by multinational
enterprises for several years. This effort, referred to as the Base
Erosion and Profit Shifting (BEPS) project, has resulted in new
OECD guidance related to tax matters including transfer pricing,
treaties and the identification and taxation of permanent
establishments. From the outset of its BEPS work, the OECD has
voiced concern about the tax challenges created by the
digitalization of the global economy. In early 2019, the OECD
issued draft proposals for new approaches to tax global digital
companies and sought comments from industry and tax authorities on
the strengths and weaknesses of these proposals. Most recently, in
May of 2019, the OECD issued the Programme of Work to Develop a
Consensus Solution to the Tax Challenges Arising from the
Digitalization of the Economy (the Digital
