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ARTICLE · 02 AUGUST 2021

Profitability Threshold

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On April 15, 2020, OECD released the report titled "Tax and Fiscal Policy in Response to the Coronavirus Crisis: Strengthening Confidence and Resilience" (the "COVID-19 Response").

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On April 15, 2020, OECD released the report titled "Tax and Fiscal Policy in Response to the Coronavirus Crisis: Strengthening Confidence and Resilience" (the "COVID-19 Response"). The COVID-19 Response discussed the decisive action many governments have taken to contain and mitigate the spread of the virus and to limit the adverse impacts on their citizens and their economies, and outlined various tax policy options as available tools. Included in the tax policy discussion is the commitment to stay the course in response to the tax challenges of the digitalisation of the economy and ensuring that MNEs pay a minimum level of tax. (p.6)  In the COVID-19 environment, the new impetus to efforts to reach agreement on Pillar One issues internationally can now stem not only from "[t]he increased use of digital services" but also from "the need to collect more revenues" which can be achieved, in part, by "strengthening the taxation of economic rents" (p.6) particularly of

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