BEPS 2.0: Issues and implications for Latin America

The new global digital environment that has emerged in recent years has driven innovation among companies, generating new ways of doing business around the world and reaching new customers and regions in a simpler way. At the same time, this new digital era has brought with it the need to review tax systems and environments and introduce new ways that allows jurisdictions to have effective tools to help promote better local tax systems and align international tax principles with current commercial reality.

In response, the Organization for Economic Cooperation and Development (‘‘OECD’’) has identified the challenges of the new economic environment as influenced by digital developments and has proposed a response to these challenges through two fundamental pillars. The OECD has set an ambitious timeline for adoption, with target implementation of 2023 for both Pillars 1 and 2 (although the Undertaxed Payment Rule of Pillar 2, discussed further in the article, is deferred until 2024).