From BEPS 1.0 to BEPS 2.0:Historical Tracing,System Construction,and Development Trends of the"Two-Pillar"International Tax Reform(Part 2)
The deep development of economic digitalization and globalization has brought a series of challenges to the international tax rules that have been in operation for a century.In response to the concerns of international community,the G20/OECD launched the BEPS 1.0 reform in 2013.Although its 15 action5 blocked the loopholes in international tax rules to some extent,they did not touch on the fundamental issues of readjustment and allocation of taxing rights between countries.To this end,the G20/OECD BEPS Inclusive Framework proposed the BEPS 2.0 reform in January 2019,referred to as the Two-Pillar Solution.This Solution consists of Pillar One to address the redistribution of specific profit taxing rights for multinational enterprises and Pillar Two to address the remaining BEPS issue.After multiple rounds of negotiations,it has been nearly fully completed.From the perspective of development trends,there is a close correlation between BEPS 1.0 and BEPS 2.0,which is mainly manifested in four aspects:comprehensively deepening governance models,adhering to the development of innovative theories,moderately breaking through rule construction,and integrating and optimizing procedural matters.Two-Pillar Solution is the result of overlaying conflicting and potentially conflicting taxing rights and new systems in the form of common technical standards on existing rules.It is a compromise plan that makes modest but significant changes to the existing international tax framework.However,it undoubtedly has epoch-making significance for the international community to seek and design a globally fair,sustainable and modern international tax paradigm system in the future.
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