The Use of Financial Accounting Information in the OECD BEPS 2.0 Project: A Discussion of the Rules and Concerns

Michelle Hanlon and Michelle Nessa

National Tax Journal, 2023, vol. 76, issue 1, 193 - 232

Abstract: This paper discusses the Organisation for Economic Co-operation and Development’s Two-Pillar proposal for changing the global international corporate tax regime. We focus on the use of financial accounting income as part of these tax rules. We provide a relatively high-level explanation of the rules, and we discuss some inconsistencies and complexities. We also discuss potential problems and unintended consequences for companies, financial statement users, tax authorities, financial statement auditors, and financial accounting standard setters as a result of using financial accounting income in the tax base.

Date: 2023
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