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OECD makes further progress in implementation of pillars one and two


Published: 18 Jul 2023 Update History

Members of the inclusive framework agree not to introduce unilateral digital services taxes before 2025.

An outcome statement agreed by 138 members of the G20/OECD inclusive framework on BEPS, published on 12 July 2023, sets out the remaining items to be resolved that relate to the formulation of amount A of pillar one (a taxing right for market countries with respect to the residual profits of the largest and most profitable multinational businesses). The text of a multilateral convention implementing this is expected in the second half of 2023. 

Countries that signed up to the statement have agreed not to introduce any unilateral digital services taxes (DSTs), designed to tax these profits domestically, before 2025. Existing DSTs can continue until then. 

The OECD also released a consultation document on 17 July 2023 on the design elements of amount B of pillar one. In particular, the consultation is seeking input by 1 September 2023 from stakeholders on the appropriateness of: 

  • the pricing framework, including the final agreement on scope;
  • the application of the framework to the wholesale distribution of digital goods;
  • country uplifts within geographic markets; and
  • the criteria to apply amount B utilising a local database in certain jurisdictions. 
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