BEPS 2.0 - Pillar One and Pillar Two: A Middle East perspective

After announcing the 15 actions in the OECD BEPS package to deal with various measures tackling profit shifting and tax avoidance, the OECD and the G20 Inclusive Framework continued directing their efforts to address the tax challenges arising from digitalisation. This OECD initiative is referred to as the BEPS 2.0.

BEPS 2.0 has two parts or pillars, namely, Pillar One and Pillar Two. Pillar One is focused on the reallocation of (a portion of) the consolidated profit of a multinational enterprise to jurisdictions where sales arise as well as the standardisation of the remuneration of routine marketing and distribution activities. Pillar Two, on the other hand, introduces a global minimum effective tax rate of 15 %.

You can find key BEPS 2.0 related updates below:

  1. Two reports on the tax challenges arising from digitalisation published by the OECD:
    - Pillar One Blueprint
    Pillar Two Blueprint

  2. Public comments on OECD Blueprints for Pillar One and Pillar Two

  3. Statement on a Two-Pillar solution to address the tax challenges arising from the digitalisation of the economy

  4. PwC's tax policy alerts on the agreement around the new international corporate tax framework:
    - From July 2020
    - From October 2020

  5. BEPS 2.0 - Pillar One and Pillar Two : A Middle East perspective

  6. Two-Pillar solution to address the tax challenges arising from the digitalisation of the economy

We will continue updating you on the latest regarding BEPS 2.0 as it happens, so stay tuned.

Contact us

Hanan Abboud

Hanan Abboud

Partner , Tax, PwC Middle East

Tel: +971 56 177 7642

Jochem Rossel

Jochem Rossel

Tax & Legal Services Leader, PwC Middle East

Tel: +971 50 225 6909

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