Navigating OECD Pillars I and II: Overseas Digital Taxation, New Nexus Determinations, Taxing Rights, and GLOBE Rules

This program has been cancelled

A live 110-minute CPE webinar with interactive Q&A

Tuesday, March 23, 2021

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

This webinar will discuss the latest Organisation for Economic Cooperation and Development (OECD) developments and its blueprints on Pillars I and II for practitioners working with global entities. Our panel of international tax veterans will explain its potential tax impact on businesses operating abroad and outline what has and has not been resolved to date in these proposals.


After initial recommendations in the base erosion and profit shifting (BEPS) report, the OECD G20 Inclusive Framework on BEPS moved to a two-pillar approach to address digitalization of the economy and multinational taxation. These may be the most substantial changes ever made to the global tax system, with OECD estimating their global impact to be as much as $80 billion.

Multinational enterprises will be significantly affected by the upcoming polices and are defined as any group that includes two or more enterprises that have tax residences in different jurisdictions or includes an enterprise that is a tax resident in one jurisdiction and subject to tax concerning business carried out through a permanent establishment in another jurisdiction. Pillar I incorporates taxing rights, nexus rules, and profit allocations, while Pillar II proposes a global minimum tax with a rate yet to be determined.

With 137 countries collaborating, the OECD hoped to reach an agreement in 2020, but challenges, including the pandemic, have delayed this date until mid-year 2021. International tax practitioners working with entities operating in multiple countries need to be familiar with and prepare for these approaching changes.

Listen as our panel of international tax experts explains the latest guidance on the OECD pillars and its impact on multinational entities, including steps companies can take now to prepare for the impending changes.



  1. Background
  2. Pillar I
  3. Pillar II
  4. Practical steps
  5. Illustrations


The panel will review these and other critical issues:

  • How will the OECD Pillars affect existing U.S. income tax treaties with other countries?
  • How is nexus determined for digital taxation under Pillar I?
  • How will the requirements be implemented and enforced?
  • How do the income inclusion and undertaxed payments rules (GLOBE) in Pillar II operate?
  • How is Amount A calculated in Pillar I?


Fuller, Pamela
Pamela A. Fuller, Esq.

Counsel (Tax, M&A, International)
Zahn Law Group

Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide...  |  Read More

Otero, Kevin
Kevin Otero

Covington & Burling

Mr. Otero advises clients across industries on all aspects of tax controversy matters including audits, administrative...  |  Read More