Ruth Mason

The 2021 Compromise

Tax Notes Federal


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.


Ruth Mason, The 2021 Compromise, 172 Tax Notes Federal 569 (2021).

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