On October 8th, 2021, an agreement between 136 countries was reached on the elements of the landmark two-pillar plan on an international tax reform addressing the tax challenges arising from the digitalization of the economy. The new statement updated the initial two-pillar agreement, which 134 member states of the OECD Inclusive Framework had agreed on July 1st, 2021. The global tax reform envisages reallocating annually more than 125 billion USD of profits from the world’s largest and most profitable multinational enterprises to market jurisdictions and ensuring that those enterprises pay a fair share of taxes in the jurisdictions they operate and generate profits in, independent of any physical presence (pillar I). Additional global tax revenues amounting to 150 billion USD on an annual basis are to be generated through the imposition of a 15 % global minimum taxation, effective from 2023 (pillar II). Stefan Bendlinger gives an overview of the building blocks of the two-pillar solution described by government officials as a “historic agreement".
