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BEPS 2.0 developments - The OECD’s blueprints on Pillar One and Pillar Two

October 2020

The OECD published the blueprints on Pillar One and Pillar Two under the tax digitalisation / globalisation project on 12 October 2020.

Pillar One looks at the attribution of profits to market jurisdictions. Pillar Two deals with the imposition of a global minimum tax. The blueprints set out the detailed technical design of various components of the two pillars but note that agreement has yet to be reached among the Inclusive Framework members. A public consultation is held from 12 October to 14 December 2020.

The HKSAR Government formed the Advisory Panel on BEPS 2.0 in June 2020 to assess the possible impact of BEPS 2.0 on Hong Kong’s competitiveness and consider the strategies and measures in response. The key policy features, principles and parameters of both pillars revealed in the blueprints would facilitate the assessment of the potential impact of BEPS 2.0 on the Hong Kong tax regime.

Our global tax team held a live webcast on 16 October 2020. PwC Hong Kong also held a webinar to share more about the blueprints from a Hong Kong perspective. If you missed it and would like to watch the playback, please contact Alice Chau at

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Contact us

Charles Lee

South China (incl. Hong Kong SAR) Tax Leader, PwC China

Tel: +[852] 2289 8899

Rex Ho

Asia Pacific Financial Services Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3026

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

Jesse Kavanagh

Hong Kong Tax Reporting & Strategy Leader, PwC Hong Kong

Tel: +[852] 2289 1100

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