Base erosion and profit shifting

Tax challenges arising from digitalisation: Public comments received on compliance and tax certainty aspects of global minimum tax


16/02/2023 – On 20 December 2022, as part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the Inclusive Framework invited public comments on the compliance and tax certainty aspects of the Pillar Two global minimum tax.

The Inclusive Framework is grateful to the commentators for their input and now publishes the public comments received.


Public consultation meeting

The public consultation meeting will be held virtually on 16 March 2023. Further information on the meeting format and how to register is available on the dedicated event page.


Further information

For more information on the OECD's public consultations on tax matters, visit


Enquiries should be addressed to [email protected].


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