All but four of the 140 countries in the OECD/G20 Inclusive Framework on BEPS (the Inclusive Framework) have accepted the so-called two-pillar plan for reform of the international business taxation system. The reform is based on a minimum 15 per cent tax rate for large multinational enterprises (MNEs), combined with new rules for the reallocation of taxing rights to national markets where MNEs have business activities and earn profits. Beneficiary countries will collect around USD150 billion in new revenues annually when the rules take full effect in 2023, the OECD has said...