With the Inclusive Framework (IF) statements of 1 July and 8 October 2021, the rationale of BEPS 2.0 seems to be cast in stone: a two-pillar approach leading to establishing new nexus and profit allocation rules as well as a minimum effective tax. This article demonstrates how the IF came to this direction of travel and provides an overview of what has happened during 8 years of discussion within the OECD and the IF.
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