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The OECD released on 31 May 2019 the Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy, agreed by the OECD/G20 Inclusive Framework (IF). The aims are broadly to have a political agreement on a unified approach by the end of 2019 and to be prepared to implement that solution by the end of 2020. Stakeholders at the US Council for International Business (USCIB) 2019 OECD International Tax Conference on 3-4 June had a first opportunity to react, amid presentations from OECD and members of the IF involved in agreeing the programme.

The G20 countries formally approved the plan on 9 June 2019 and will help steer political engagement and endorsement. The Steering Group of the IF, supported by its Task Force on the Digital Economy (TFDE), will focus on reaching agreement on a unified approach. OECD Working Parties (particularly WP1, 6, 10 and 11) and the Forum on Tax Administration (FTA) Mutual Agreement Procedure (MAP) Forum will provide technical inputs. The OECD Secretariat will undertake an economic analysis and impact assessment through its WP2.

The OECD will hold public consultations for external feedback if necessary, although given the tight time frame of the project consultation periods may be short. There will be a progress report and a final report, in line with the above aims, in December 2019 and December 2020 respectively. 

The work programme stipulates a large number of fundamental issues to consider in the short time frame available. In this Bulletin, we seek to provide insight on the potential impact of the programme, starting with the February/ March 2019 consultation on the project then discussing the Pillar 1 considerations, Pillar 2 considerations and impact assessment to be. Stakeholders may wish to consider whether to engage unsolicitedly with the OECD and member countries in order to make their views known.