BEPS Inclusive Framework Members Agree on Package of Deliverables to Address the Remaining Elements of the Two‐Pillar Solution

The OECD has announced that 138 members of the BEPS Inclusive Framework have agreed on an Outcome Statement summarizing the package of deliverables developed to address the remaining elements of the Two‐Pillar Solution, including:

• a multilateral convention that allows jurisdictions to reallocate and exercise a domestic taxing right over a portion of MNE residual profits (Amount A of Pillar 1);
• a framework for the simplified and streamlined application of the arm's length principle to in-co…