This chapter examines the response proposed by the OECD Secretariat to the challenges to the international tax framework posed by the digital economy. The challenges are very different because some, such as the allocation of taxing rights and taxable nexus, are comparatively recent challenges emerging from the enormous success of the digitalisation of the economy. As companies have been able to secure massive business advantages from the network effect, the use of data, the role of users and the ability of business to identify customer needs, so has the need to address taxation on remote sales become more urgent. Pillar One, with its proposal to allocate taxing rights to the market jurisdiction in circumstances where there is no physical presence, is a key part of this response. Other challenges, such as the issues in tax competition and transfer pricing, are more generic and long-standing. These are addressed by Pillar Two using broad-brush remedies against base erosion and profit shifting. They can be seen as a backstop to the more specific actions proposed by the BEPS 15 point Action Plan.

This chapter examines the response proposed by the OECD Secretariat to the challenges to the international tax framework posed by the digital economy. The challenges are very different because some, such as the allocation of taxing rights and taxable nexus, are comparatively recent challenges emerging from the enormous success of the digitalisation of the economy. As companies have been able to secure massive business advantages from the network effect, the use of data, the role of users and the ability of business to identify customer needs, so has the need to address taxation on remote sales become more urgent. Pillar One, with its proposal to allocate taxing rights to the market jurisdiction in circumstances where there is no physical presence, is a key part of this response. Other challenges, such as the issues in tax competition and transfer pricing, are more generic and long-standing. These are addressed by Pillar Two using broad-brush remedies against base erosion and profit shifting. They can be seen as a backstop to the more specific actions proposed by the BEPS 15 point Action Plan.