Base erosion and profit shifting

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


OECD/G20 Statement IF cover


Published: 31 January 2020


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The OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), which groups 137 countries and jurisdictions on an equal footing for multilateral negotiation of international tax rules, decided during its 29-30 January 2020 meeting to move ahead with a two-pillar negotiation to address the tax challenges of digitalisation. 

In light of the strong support from the Inclusive Framework members for reaching a multilateral agreement with respect to Pillar One and Pillar Two, and drawing on the technical work of the Working Parties, comments from the public consultation, as well as the discussion at a number of Steering Group meetings, and recognising the concurrent work on a without prejudice basis on the two pillars, members of the Inclusive Framework affirm their commitment to reach an agreement on a consensus-based solution by the end of 2020. In further developing the two Pillars, the Inclusive Framework has therefore agreed upon an outline of the architecture of a Unified Approach on Pillar One as the basis for negotiations and welcomed the progress made on Pillar Two (which follows the outline of Pillar Two in the PoW) contained in Annexes 1 and 2 of this statement.


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