OECD launches public consultation on the tax challenges of digitalisation with the release of a first building block under Pillar One


04/02/2022 - Following the agreement reached in October 2021 by over 135 members of the OECD/G20 Inclusive Framework on BEPS to a two-pillar solution to address the tax challenges arising from digitalisation and globalisation of the economy, work on the implementation of the two-pillar plan is well underway. As part of this next phase, the Inclusive Framework will consult stakeholders on a number of aspects of Pillar One and Pillar Two over the coming months.


Pillar One

For Amount A of Pillar One, the Inclusive Framework is launching a public consultation that will occur in stages, by releasing Secretariat working documents on each building block to obtain feedback quickly and before the work is finalised. This approach, rather than waiting for a comprehensive document to be ready, will allow work to continue in parallel, in order to remain within the political timetable agreed in October 2021.


Today the first building block is released for public comments. The Draft Rules for Nexus and Revenue Sourcing have been agreed for release by the Inclusive Framework to obtain public comments, but the draft rules do not reflect consensus regarding the substance of the document. Interested parties are invited to send their written comments no later than 18 February 2022.


For Amount B of Pillar One, a public consultation document will be issued in mid-2022, with a public consultation event to follow the comment period.


Pillar Two

The Pillar Two Model Rules issued in December 2021 provide a template for domestic implementation of the GloBE Rules. These Rules will be supported by a Commentary to provide tax administrations and taxpayers with guidance on the interpretation and application of those Rules, which is currently under development, also drawing on input from a Business Advisory Group set up by BIAC.


An Implementation Framework is being developed to facilitate the co-ordinated implementation of the GloBE rules and will address administrative and compliance issues, including the development of safe harbours. A public consultation on the Implementation Framework will be launched later this month, with a consultation event to follow in March.


For the Subject to Tax Rule (STTR) of Pillar Two, the draft model provision and its commentary will be released in March 2022 with a defined set of questions set for input. A public discussion draft on the development of a multilateral instrument to facilitate the implementation of the STTR would also be released for comment at the same time. 


Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at


Enquiries should be directed to Achim Pross (+33 1 45 24 98 92), Head of CTPA’s International Co-operation and Tax Administration Division or to