Disruptive Profit Allocation Methods for Disruptive Businesses?! (Part I)

In February 2019, the OECD launched a Consultation Document on the digitalisation of the economy indicating a way forward based on two pillars (revised nexus and profit allocation rules, and global anti-base erosion approaches), followed by a Public Consultation on March 15^th and 16^th, 2019. Finally, the OECD published a Programme of Work to develop a consensus solution to the tax challenges arising from the digitalisation of the economy on May 31^st, 2019.