With much pomp and ceremony, it was announced that member jurisdictions of the G20/OECD BEPS Inclusive Framework “agreed to a two-pillar solution to address the tax challenges from the digitalization of the economy” (the “Two-Pillar Agreement”) This agreement has been hailed by some as “historic”, “momentous”, “revolutionary”, but criticized by others as “harmful to developing countries”, cartelistic power grabbing by a few powerful countries, or neocolonialism. So, is the agreement a cause for celebration or the opposite? What is the chance of the Agreement become real law? In this article, I try to first explain what the two-pillar agreement is and then offer my views on the truths and realities of the Agreement. Readers are invited to draw their own conclusions about the implications and the future of the Agreement.
Li, Jinyan, "The Global Tax Agreement: Some Truths and Legal Realities" (2022). All Papers. 343.