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The challenges of taxing the digital economy and the need for consensus at the domestic level

Updated: Mar 15, 2023

The Base Erosion and Profit Shifting (BEPS) Project of the Organisation for Economic Co-operation and Development (OECD) and the G20 created the BEPS Inclusive Framework in June 2016 to ensure that interested countries, including emerging countries, can participate on an equal footing in the development and implementation of BEPS standards.


The implementation of these BEPS standards within the Inclusive Framework entails the adoption of so-called "minimum standards", which provide for the implementation of four priority actions of the Inclusive Framework:


- Action 5: Combat harmful tax practices, taking into account transparency and substance.

- Action 6: Prevent abuse of double taxation treaties.

- Action 13: Transfer pricing documentation and country-by-country reporting.

- Action 14: Make dispute resolution mechanisms more effective.



However, in order to assess the progress of the BEPS standards in the countries, the eleventh meeting of the Inclusive Framework of the OECD-G-20 BEPS Project was held on 27 and 28 January 2021, with the participation of 137 member countries of the Inclusive Framework. One of the objectives of the meeting was to reach a global solution based on consensus for the taxation of the digital economy.


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