OECD-Proposal: New Allocation of Taxing Rights

On 9 October 2019 the OECD-Secretariat presented its public consultation document for a "Unified Approach under Pillar One".² This Pillar One focuses on the allocation of taxing rights and seeks to undertake a coherent and concurrent review of the profit allocation and nexus rules.³ In the digital age, the allocation of taxing rights can no longer exclusively depend on physical presence.