Within the framework of Pillar One of the OECD-BEPS 2.0 project, the international community of states is discussing a reallocation of taxing rights from production states to market states. This article deals with the mechanism to avoid double taxation and the determination of those states that must contribute from their tax revenues. Furthermore, it explores the possibilities of constitutional and administrative implementation into German law. The author presents conceptual approaches for a dispute-free and predictable design and advocate a centrally consolidated legal and administrative implementation. In July 2021, the Organisation for Economic Co-operation and Development (OECD) reached a broad agreement at a working level for an international tax reform. The focus is on introducing fair allocation rights and a global, uniform minimum tax rate of at least 15%. Details of the so-called Two-Pillar model are being sought. Additionally, information on the roadmap for implementing the developed concept and the current status of implementation is requested. For both pillars, the lack of international coordination would lead to double and multiple taxation and, undoubtedly, a significantly higher administrative burden. In such a scenario, companies would have to comply with a multitude of different national regulations concerning their cross-border activities, ultimately resulting in multiple taxation. It raises the question on how this geolocation is supposed to be carried out.
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