After explaining the classic nexus rules based on physical presence, adapted to traditional economies, the presentation pointed out their basic shortcomings in the context of today's digitalized economy. As a continuation of the work started on BEPS Action 1, and with the intention of eliminating or mitigating the aforementioned shortcomings, the OECD, through the Inclusive Framework, has approached the reform of the rules of international taxation by implementing the "two pillars" plan, which would ensure that multinational companies pay their fair share of taxes wherever they do business. In the framework of the presentation, the solutions envisaged by the Second Pillar were further presented. It was analyzed what this process means for Serbia and its tax system.