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Deloitte OECD Pillar One Modeling

An integrated modeling approach to help you understand the tax challenges arising from digitalization.

What is OECD Pillar One?

The OECD Pillar One proposal would dramatically change a century of international tax principles by creating new taxing rights that would reallocate income to jurisdictions without permanent establishments and without regard to the arm’s length principle. It targets large, automated service and consumer-facing (digital and non-digital) businesses. If adopted in tax treaties and local legislation, the proposal can have far-reaching impact to many Multinational Enterprises (MNE’s) for years to come.

Deloitte OECD Pillar One Modeling

Dashboard highlights

The Deloitte OECD Pillar One Model helps you understand the various tax implications arising from digitalization through analytics dashboards.

OECD Model


The Model features

  • Excel-based model: Using Excel with advanced VBA allows for a nimble, flexible, transparent, and customizable tax-modeling solution.
  • Simple inputs: Supports flexibility in the inputs, starting with CbCR and other easily-accessible data, and having an option to further refine the model with additional data.
  • Default selections: Default selections included for most of the Pillar One assumptions based on select public comments made by governmental agencies in various countries and other stakeholders. Inputs may be tailored based on specific facts and circumstances.
  • Built-in calculation toggles: Due to uncertainties in the OECD proposal, toggles are used for items such as whether to calculate Amount A by business segment or on a consolidated basis, and whether to allocate Amount A by sales, users, or a user defined metric.
  • Scenarios and enhancements: Save and analyze dozens of scenarios, providing critical insight into the different ways Pillar One may unfold and impact your organization.
  • Intuitive visuals: Visualized dashboards tell the story of how the proposal affects your tax posture.
  • Evolving with Pillar One: Helps adapt to changes through refreshed modeling through the evolution of Pillar One.

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Our team

Our dedicated global tax policy team closely monitors both the latest OECD and local-country developments. They support client service teams to provide meaningful and insightful modeling, while bringing the latest strategic perspective from broad experience.

By teaming with you, we can help you make informed assumptions in the OECD Pillar One Model and explore future planning opportunities.

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