Member area

TUAC Response to the OECD Public Consultation on Tax Challenges of Digitalisation

14 December 2020

TUAC welcomes the opportunity to contribute to the OECD consultation on Pillar One and Pillar Two Blueprints. This publication follows the November 2019 consultation on a proposed unified approach to address the tax challenges of the digitalisation of the economy, and the December 2019 consultation on Global Anti-Base Erosion proposal.

The present consultation focuses on the technical aspects of the Blueprints, leaving aside key features which, according to the consultation document, should be resolved by a high level political process. This is regretful. Limiting consultation to technical aspects favours tax consultants and tax lawyers. It does not allow other representative stakeholders to the broader policy orientation and general design of the Blueprints.

The political and economic landscape have significantly evolved in the past twelve months, in particular in the light of the financial impact of the pandemic. As governments are preparing their recovery, it is important for the Inclusive Framework to strengthen its legitimacy and to consult widely with a view to ensure that international tax reform meets public expectations. On the general design of the Blueprints, our recommendations are as follows:

  • A decoupling of the two Pillars. Reaching an ambitious agreement under Pillar 2 should be treated as a priority as this would limit tax competition between countries and help raise tax revenues. More work is needed on Pillar 1, including to address complexity and impact.
  • Ensuring a robust agreement on Pillar 2 would also give countries the breathing space towards a global excess profit tax in addition to a more fundamental reform of the current international taxation rules.

read the TUAC submission in the attached PDF file.