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Business structures and the process of value creation have evolved in part through the digitalization of the global economy. Such evolution has posed broad tax challenges which the Organization for Economic Cooperation and Development (OECD) is currently evaluating. Sometimes referred to as BEPS 2.0, the OECD is examining various proposals concerning changes to current profit allocation and
nexus rules, as well as a global minimum tax, which were first detailed in a consultation document.

Additionally, on 31 May 2019, the OECD released a work plan, Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy, stating that it expects to provide a long-term, consensus-based solution in 2020. A further document, as well as a public consultation, are expected later this year.

In addition to the OECD’s efforts, separate unilateral measures addressing the digitalization of the economy have been introduced by a variety of countries,
including France and the United Kingdom.