After a brief explanation of the classical nexus rules based on physical presence, designed with the traditional economies in mind, the presentation addressed their main flaws and drawbacks in the context of today’s digitalized economy. As a continuation of the work on BEPS Action 1 and with the intention of remedying the discussed flaws and drawbacks, OECD has, through the Inclusive framework, initiated a reform of rules of international taxation through the implementation of the Pillar 1 and Pillar 2. These initiatives are directed at enabling that the fair share of taxes is paid by MNEs wherever their business activities are located. The presentation analysed the main features and solutions of the Pillar 2 and addressed potential issues that it could raise for the Serbian tax system.

• Prof. Dr. Dejan Popović, Faculty of Law, University of Belgrade
• Mag Dragan Drača, partner at PwC Serbia