Digitalisation has transformed the way businesses create value, interact with customers and operate across borders. As business models evolve and economic activity becomes increasingly global and digital, governments face questions about how international tax rules should apply in a changing economy. The digitalisation of the economy has highlighted broader challenges for international tax systems.
BEPS Action 1 Tax Challenges Arising from Digitalisation of the Economy
The tax implications of the digitalisation of the economy have been a major focus of international tax co-operation under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). This work aims at ensuring that tax systems remain effective in an increasingly digital and globalised economy.
Last updated: December 2025
Key messages
Effective and internationally co-ordinated tax rules help provide certainty for governments, businesses and investors. In an increasingly interconnected world, jurisdictions need common approaches that reduce the risk of double taxation, minimise opportunities for tax avoidance and support a stable international tax environment. Addressing the tax implications of digitalisation is therefore an important part of ensuring that international tax rules remain fit for purpose and continue to support economic growth, investment and cross-border trade.
The OECD has been at the centre of international efforts to analyse and address the tax implications of digitalisation through the OECD/G20 Inclusive Framework on BEPS. This global collaboration across 145+ jurisdictions has produced extensive technical analysis, reports, standards and guidance, supporting jurisdictions in responding to emerging tax challenges and strengthening international tax co-operation.
Today, the Inclusive Framework continues to provide a platform for jurisdictions to discuss and develop practical solutions to international tax challenges arising from an increasingly digitalised and globalised economy, while promoting tax certainty, effective implementation and a more stable international tax system.
What are the results so far?
Considering the importance of the challenge and understanding that global consensus is the target, we have made substantial progress. Key milestones accomplished so far in this work include:
- October 2015: BEPS Action 1 - Addressing the Tax Challenges of the Digital Economy
- March 2018: Delivery of the Interim Report
- January 2019: Delivery of Policy Note
- February-March 2019: Public Consultation
- May 2019: Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy
- November 2019: Public Consultation - Secretariat Proposal for a "Unified Approach" under Pillar One
- December 2019: Public Consultation - Global Anti-Base Erosion (GloBE) Proposal under Pillar Two
- January 2020: Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalisation of the Economy
- October 2020: Statement by the OECD/G20 Inclusive Framework on BEPS and delivery of the reports on the Blueprints of Pillar One and Pillar Two, and the Economic Impact Assessment.
- October-December 2020: Public Consultation - Reports on the Pillar One and Pillar Two Blueprints
- January 2021: Public Consultation Meeting - Reports on the Pillar One and Pillar Two Blueprints
- July 2021: Statement on a Two–Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy
- October 2021: Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy
- December 2021: Global Anti-Base Erosion Model Rules (Pillar Two)
- Early 2022: Public consultations on the implementation aspects of Pillar One and Pillar Two
- March 2022: Commentary to the GloBE Rules
- Early 2022: Public consultations on the implementation aspects of Pillar One and Pillar Two
- July 2022: Public consultation on the Progress Report on Amount A under Pillar One
- October 2022: Public consultation on the Progress Report on the Administration and Tax Certainty Aspects of Amount A under Pillar One
- December 2022: Public consultation on Amount B under Pillar One
- December 2022: Public consultation document on Pillar One - Amount A: Draft Multilateral Convention Provisions on Digital Services Taxes and Other Relevant Similar Measures
- December 2022: Implementation package for Pillar Two
- February 2023: Agreed Administrative Guidance for the Pillar Two GloBE Rules
- July 2023: Outcome Statement on the Two–Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy
- July 2023: Public consultation on Amount B under Pillar One
- July 2023: Agreed Administrative Guidance for the Pillar Two GloBE Rules
- July 2023: GloBE Information Return (Pillar Two)
- July 2023: Subject to Tax Rule (Pillar Two)
- October 2023: Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI)
- October 2023: Minimum Tax Implementation Handbook (Pillar Two)
- October 2023: Multilateral Convention to Implement Amount A of Pillar One
- December 2023: Agreed Administrative Guidance for the Pillar Two GloBE Rules
- December 2023: Update to Pillar One timeline by the OECD/G20 Inclusive Framework on BEPS
- February 2024: Pillar One - Amount B
- May 2024: Statement by the Co-Chairs of the Inclusive Framework
- May 2024: Statement by the OECD Secretary-General on the 16th Inclusive Framework meeting
- June 2024: Inclusive Framework taking further steps on the implementation of the Two-Pillar Solution
- September 2024: Inclusive Framework takes a further step on the implementation of Amount B of Pillar One
- December 2024: New tools for the implementation of Amount B
- January 2025: Statement: Pillar One Update from the Co-Chairs of the Inclusive Framework
- April 2025: Statement by the Inclusive Framework following its Cape Town plenary
