The Unified Solution to BEPS Challenges in the New Economy: Update on Pillar One and Two (Completed)

Date: Thursday, February 25, 2021
Instructor: William J. Seeger
Begin Time:  11:00am Pacific Time
12:00pm Mountain Time
1:00pm Central Time
2:00pm Eastern Time
CPE Credit:  1 hour for CPAs
1 hour Federal Tax Related for EAs and OTRPs
1 hour Federal Tax Law for CTEC

The Organization for Economic Cooperation and Development (OECD) finalized the Base erosion and profit shifting (BEPS) initiative in 2015. BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to make profits 'disappear' for tax purposes or shift profits to locations with little or no real activity. A significant challenge for the BEPS initiative is the digital economy's taxation due to a lack of physical nexus. With its attendant networks and linkages, a Digitally based economy generates economic growth without bricks and mortar. This development introduces a challenge to taxation based on physical presence. The OECD proposes a unified approach, Pillar One and Pillar Two, to mitigate the tax challenges posed by a unified, integrated, digital economy. Pillar One focuses on nexus and profit allocation. Pillar Two focuses on a global minimum tax intended to address remaining BEPS issues.

This webinar considers this controversial Unified Approach in detail and critically assesses each pillar's methodology in response to BEPS challenges.

Who Should Attend
Tax Directors, Tax Staff, Transfer Pricing Practitioners, Treasury, Internal Auditors, CPAs, and CFOS.

Topics Covered

  • What is the impact of the Digital Economy on International Taxation?
  • Virtual Nexus vs. Physical Nexus
  • The OECD Unified Approach
  • OECD Pillar One and Pillar Two
  • Arm's Length Standard vs. Formulary Apportionment
  • Global Minimum Tax
  • Mutual Agreement Procedure and Multi-lateral Convention

Learning Objectives

  • Recognize how the digital economy and digital economy business models work
  • Differentiate between digital and physical nexus
  • Describe broadly the the fifteen (15) BEPS articles, especially Article 1 on the Digital economy
  • Describe the Unified Approach to tax the Digital economy: Pillar One and Two
  • Identify the new taxing right under Pillar One
  • Recognize how Pillar One erodes the Arm's Length Standard as the basis for International Taxation
  • Identify the prevention of aggressive unilateral measures and the intense political pressure to tax highly digitalized Multi-national businesses
  • Describe what the future of multilateral tax co-operation will look like


Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (1 hour)

Program Prerequisites

Advance Preparation

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