The 2021 Compromise

172 Tax Notes Fed. 569 (2021)

7 Pages Posted: 16 Aug 2021 Last revised: 17 Aug 2021

See all articles by Ruth Mason

Ruth Mason

University of Virginia School of Law

Date Written: July 26, 2021


This article provides historical background that helps explain the agreed proposals among the OECD Inclusive Framework countries on Pillars 1 and 2. It also discusses the goals behind Pillar 1, which proposes a new tax nexus based on demand, and Pillar 2, which proposes a harmonized minimum corporate tax. This article seeks to explain the differing interests of the various countries involved in the negotiation, and it identifies the most important aspects of the proposals. Contrary to arguments made by some NGOs, this article argues that the 2021 Compromise represents meaningful change, even though it principally benefits wealthy countries.

Keywords: BEPS, corporate tax avoidance, profit shifting, digital tax, minimum tax

Suggested Citation

Mason, Ruth, The 2021 Compromise (July 26, 2021). 172 Tax Notes Fed. 569 (2021), Available at SSRN:

Ruth Mason (Contact Author)

University of Virginia School of Law ( email )

United States

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