Remarks on the Future Prospects of the OECD/G20 Programme of Work – Profit Allocation (Pillar One) and Minimum Taxation (Pillar Two)

Abstract

This article examines the OECD/G20 programme of work dealing with the tax challenges arising from the digitalization of the economy, highlights the partial abandonment of the arm’s length principle, discusses two ways of minimum taxation, evaluates the obstacles to international tax coordination and considers the possible consequences for national tax policy.