Abstract

This study explores the phenomenon of Base Erosion and Profit Shifting (BEPS) within the framework of Tanzanian taxation. It places a specific focus on the intricate Two-Pillar Solution proposed by the OECD to tackle BEPS-related challenges. The analysis encompasses an in-depth investigation of BEPS itself and a thorough examination of the OECD's Two-Pillar Solution, which encompasses the novel nexus and profit allocation rules under Pillar One and the proposition of a minimum global tax under Pillar Two. Furthermore, the study delves into the evolving global trend toward multilateralism in the realm of international taxation. The research concludes by presenting recommended solutions and offering insights into the future landscape of BEPS-related issues, while also providing valuable observations on the subject matter. This paper adopts a doctrinal approach and draws upon primary and secondary sources of literature, including Tanzanian tax laws, OECD guidelines, and other international principles. It is expected to be a valuable resource for policymakers, academics, think tanks, the academic community, tax departments, international trade entities, digital taxation stakeholders, online businesses, and the judiciary, facilitating a deeper understanding of BEPS and its implications.

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