In the course of the last years, the OECD extensively dealt with tax issues generated by the increasing digitalisation of business models. While the focus on BEPS action 1 was clearly on the taxation of “digital business", the OECD constantly enlarged the potential scope of its contemplations via “digitalised businesses" and finally ended up with a focus on “consumer-facing businesses" in the recent Secretariat Proposal of a “Unified Approach" under Pillar One.

