In the OECD’s recently published “Tax Challenges Arising from Digitalisation – Report on Pillar One", the new taxation proposal for international corporate taxation is taking shape. Over the years, the OECD constantly enlarged the potential scope of its contemplations via “digitalised businesses" and “digital business models", and ended up with a focus on “automated digital services" and “consumer-facing businesses". The proposal, if implemented accordingly, would result in more taxation rights regarding corporate profits for market states. Therefore, the taxation rights would move from the state of residence to the market state. This represents a paradigm shift in international corporate taxation.
