More than 110 countries and jurisdictions agreed to review two key concepts of the international tax system, responding to a mandate from the G20 Finance Ministers to work on the implications of digitalisation for taxation.

The members of the OECD/G20 Inclusive Framework on BEPS are working towards a consensus-based solution by 2020, as set out in their Interim Report on the Tax Challenges Arising from Digitalisation.

Building on the 2015 BEPS Action 1 Report, the Interim Report includes an in-depth analysis of the changes to business models and value creation arising from digitalisation, and identifies characteristics that are frequently observed in certain highly digitalized business models. Describing the potential implications for the international tax rules, the Interim Report identifies the positions that different countries hold, which drive their approach to possible solutions. These approaches range from those countries that consider no action is needed, to those that consider there is a need for action that would take into account user contributions, through to others who consider that any changes should apply to the economy more broadly. The Interim Report lays the ground to move forward at the OECD towards a long-term multilateral solution in the next phase of work.

“The international community has taken an important step today towards resolving the tax challenges posed by the digitalisation of the economy,” said Mr Gurría. “We have underlined the complexity of the issues, and highlighted the importance of reaching international agreement, both for our economies and the future of the rules-based system. The OECD stands ready to accompany countries as they seek to build a common understanding of the issues related to the digital economy and taxation, as well as the long-term solutions.”

Under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, a number of important new standards were delivered aimed at tackling double non-taxation.  Country-level implementation of the wide-ranging BEPS package is already having an impact, with evidence emerging that some multinationals have already changed their tax arrangements to better align with their business operations. The measures are already delivering increased revenues for governments – for example, over 3 billion euros in the European Union alone as a result of the implementation of the new International VAT/GST Guidelines. Despite this success in tackling BEPS, the Interim Report underlines that many countries believe challenges to the international tax system still remain.

Inclusive Framework members recognise that they share a common interest in maintaining a single, relevant set of international tax rules.  As part of the next phase of their work, they have agreed to undertake a coherent and concurrent review of the “nexus” and “profit allocation” rules – fundamental concepts relating to the allocation of taxing rights between jurisdictions and the determination of the relevant share of the multinational enterprise’s profits that will be subject to taxation in a given jurisdiction. In exploring potential changes, members would consider the impacts of digitalisation on the economy, relating to the principles of aligning profits with underlying economic activities and value creation.

While agreeing to work towards a long-term solution by 2020, some countries believe that there is a strong imperative to act quickly and are in favour of the introduction of interim measures, while other countries are opposed to them and consider that such measures will give rise to risks and adverse consequences. Those countries in favour have identified a number of considerations that they believe need to be taken into account to limit the possible adverse side-effects.

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