Pillar One Reforms

In recent times, the digitization of business has taken massive strides and successfully infiltrated almost all areas of commerce around the world. Unfortunately, measures aimed at regulating the novel business methods accompanying digitization have not kept pace with such progress. The negative impact of this has been most evident in taxation, especially in profit shifting. The OECD, at the centre of these developments, has been advancing its BEPS Project and Action Plan to counter multinational enterprises attempting to avoid or reduce their taxation liability in countries in which they generate their profits, mostly by selling their products and services. Pillars One and Two are currently proceeding under the auspices of the OECD. However, the speed at which Pillar Two is being implemented is far more conspicuous and palpable than in the case of Pillar One. The accelerated pace for Pillar Two was evident recently when the UK government released draft legislation together with explanatory notes, with the view to incorporating Pillar Two into its Tax Code. This move is in line with the decision of the UK government to bring forward the intended implementation of Pillar Two to 2024. The legislative changes are expected to be incorporated into the UK Finance Bill 2022/23.