BEPS Pillar One and Pillar Two

Insights from KPMG about the potential impact of proposed tax reforms to address the changing global economy

Manal Corwin

Manal Corwin

Principal in Charge, Washington National Tax, KPMG US

+1 202-533-3127

Brett Weaver

Brett Weaver

ESG Tax Leader, KPMG US

+1 206-913-6697

The challenge of how to tax the digital economy was identified in the OECD's BEPS initiative as Action 1: Addressing the Tax Challenges of the Digital Economy. The OECD/G20 Inclusive Framework on BEPS (IF) has largely achieved a consensus around a long-term two-pillar solution to address taxation of the digital economy. At the same time, some countries are taking unilateral actions, such as imposing digital services taxes. As the digitization tax debate continues, multinational companies will need to stay abreast of both short- and long-term developments to navigate and prepare successfully for the resulting changes to the global tax landscape. You'll find insights about these developments from KPMG on this page.

Implementation Package

Analysis of December 20th Pillar Two GloBE rules implementation package

Analysis of December 20th Pillar Two GloBE rules implementation package

Pillar Two Implementation

Overview of the impact of the OECD’s Pillar Two initiative on U.S. multinational groups

Overview of the impact of the OECD’s Pillar Two initiative on U.S. multinational groups

TaxNewsFlash Alerts

KPMG reports of tax treatment of the digital economy

KPMG reports of tax treatment of the digital economy

Future of the Arm's-Length Principle

September 26, 2022

The arm’s-length principle has been the cornerstone of the international tax system for about a century; that system is now in a state of flux and seems under threat. Read this article series that reassesses merits of the arm’s-length principle and significant problems with global formulary apportionment—the perceived alternative. They also consider the impact that OECD initiatives may have on the future of transfer pricing.

Pillar Two Checklist

August 2022

Is your tax team on top of possible global minimum tax requirements? review our checklist to get started or to help determine where gaps may exist in your tax department's efforts to be prepared for the possible Pillar Two changes.

Webcasts & podcasts

 

 

KPMG TaxRadio podcasts

KPMG BEPS 2.0 Model: Assessing the Impact on Your Organization
International Tax professionals from across the global network of KPMG International firms can help clients understand, communicate, and evaluate appropriate actions in light of the BEPS 2.0 initiative. Using the KPMG BEPS 2.0 Model, we can assist in analyzing how the proposals may affect your organization and give you the insights you need for effective tax planning.
BEPS 2.0: What You Need to Know
Read this summary to learn more about the BEPS 2.0 two-pillar approach, its potential impacts, and how KPMG professionals from member firms worldwide can help.
Pillar One: Profits Allocations and Nexus (October 2021)
One-page summary of Pillar One, which aligns taxing rights with local market engagement
Pillar Two: Global Minimum Taxation (December 2021)
Summary of Pillar Two, which establishes a global minimum taxation regime through a series of interlocking rules