The Tax Foundation is the nation’s leading independent tax policy research organization. Since 1937, our principled research, insightful analysis, and engaged experts have informed smarter tax policy at the federal, state, and local levels.
The Tax Foundation is the nation’s
leading independent tax policy
research organization. Since 1937,
our research, analysis, and experts
have informed smarter tax policy at
the federal, state, local, and global
levels. We are a 501(c)(3) nonprofit
©2019 Tax Foundation
Creative Commons CC-BY-NC 4.0
Editor, Rachel Shuster
Designer, Dan Carvajal
1325 G Street, NW, Suite 950
Washington, DC 20005
Summary and Analysis of the
OECD’s Work Program for BEPS 2.0
• The OECD is continuing its work to develop proposals that could change
international taxation rules.
• The current work program focuses not only on policies that would impact
how much multinational businesses pay in tax, but also which countries that
tax will be paid to.
• The policies being considered raise numerous questions of administrability,
compliance costs, and coordination.
• The OECD should work toward a solution that creates stability for the
international tax system while not pursuing policies that could drive
distortions for business activity.
Director of Global Projects
TAX FOUNDATION | 2
On May 31, the Organisation of Economic Co-operation and Development (OECD) released its
work program1 on addressing the tax challenges of digitalization. This work follows on the heels of
the OECD/G20 Base Erosion and Profit Shifting (BEPS) project and is in some ways a continuation
of that work. The work program identifies options to change rules that define where multinational
businesses pay taxes and policies that would put in place worldwide minimum taxation for
The current effort is being made not only by the G20 and OECD countries, but also by the Inclusive
Framework (IF) on BEPS.2 This is a group of 129 countries3 that is working to implement changes to
international tax rules.
The work plan outlines various approaches and questions that need to be addressed by the end of