Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy

Members of the OECD/G20 Inclusive Framework on BEPS (IF) took a major step forward with the agreement on the Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy. This Programme of Work provides detailed instructions to the IF and its technical working groups to deliver a solution to the tax challenges brought by digitalisation. This work focuses on two pillars. The first pillar is about the allocation of taxing rights, and seeks to undertake a coherent and concurrent review of the profit allocation and nexus rules. The second pillar focuses on the remaining BEPS issues and seeks to develop rules that would provide jurisdictions with a right to “tax back” where other jurisdictions have not exercised their primary taxing rights or the payment is otherwise subject to low levels of effective taxation.