Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS) project of 15 reports.  In 2005, ten years before the BEPS reports, the OECD published E-commerce: Transfer Pricing and Business Profits Taxation to…

1. Purpose of the blog This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE business models in light of the “ongoing work” of the OECD with respect to the digitalization of the economy[1]. The reader…

1. Purpose of the contribution The purpose of this contribution is to address the impact of the Pillar I debate on principal structures or centralized business models. The tentative assessment will be made in light of the “ongoing work” of the OECD with respect to the digitalization of the economy[1]. 2. Illustration of a typical…