Statement on a Two-Pillar Solution to Address the Tax Challenges arising BEPS 2.0: Pillar 1 and Pillar 2
The G20/OECD Inclusive Framework on BEPS (“IF”) has, on 1 July 2021, approved the “Statement on a Two-Pillar Solution to Address the Tax Challenges Arising From the Digitalization of the Economy” (the “Statement” or so called “BEPS 2.0”). The Statement is approved by 133 countries and jurisdictions of the 139 countries and jurisdictions comprising the IF, including Hong Kong and China, as of 12 August 2021.
The Statement sets forth the key terms for an agreement of the two-pillar approach to reform and to calls for a comprehensive agreement by the October 2021 G20 Finance Ministers and Central Bank Governors meeting, with changes coming into effect in 2023.
The Statement diverges in important respects from the Pillar 1 and Pillar 2 Blueprints, released for consultation in October 2020. However, in several respects, the Statement builds on the Blueprints and resolves some of the key open items from the Blueprints.
For prior coverage of the Pillar 1 Blueprint, please refer to our Tax Newsletter issued in January 2021. On Pillar 2, our Tax Newsletter issued in July 2021 has already covered the resolutions addressed in the Statement.
