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Consultation document released on tax challenges of digitalization

  • OECD (Organisation for Economic Co-operation and Development) Image

Feb 13, 2019

On February 13, 2019, as part of the ongoing work of the OECD/G20 inclusive framework for the global implementation of the BEPS project, the Organisation for Economic Co-operation and Development (OECD) released a consultation document "Addressing the Tax Challenges of the Digitalization of the Economy." Comments are requested by March 1, 2019.

The consultation document sets out four proposals under consideration by the members of the inclusive framework as they work towards reaching a new consensus-based long-term solution in 2020. Options under consideration are:

  • Three proposals to revise existing profit allocation and nexus rules based on the concepts of (i) "user participation," (ii) "marketing intangibles" and (iii) "significant economic presence;" and
  • A global anti-base erosion proposal comprising income inclusion and denial of deduction rules to permit countries to tax profits where income is subject to no or very low taxation.

The consultation document makes clear that countries have agreed to look at a range of proposals on a "without prejudice" basis to allow for necessary further work without commitment at this stage to a particular course of action.

Review a summary and the consultation paper consultation paper on the OECD's website.

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