The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...

The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This...

This paper will review themes arising from the OECD/G20 BEPS project and the final deliverables published in October 2015. The author examines some reverberations from the final deliverables and post-BEPS developments. The author questions whether the final deliverables address the problems...