Pillar One
Pillar One is the first part of the OECD/G20 Two-Pillar Solution. It is designed to allocate a share of the profit of the very largest and most profitable multinationals to the countries where their customers are, regardless of physical presence. Its main component, Amount A, applies only to groups with global revenue above €20bn and profitability above 10%, and would reallocate 25% of profit above that 10% threshold to market jurisdictions in proportion to their share of revenue. It is meant to replace the patchwork of unilateral Digital Services Taxes. As of 2026 it remains unimplemented globally: the US has not ratified the treaty and negotiations are stalled, so countries keep relying on DSTs instead.
ByLoopholeKiln EditorialPublished
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Example: a tech giant earning large revenue in the UK but booking its profit elsewhere would, under Pillar One, give the UK taxing rights over a slice of the profit tied to UK customers, which the lack of implementation currently blocks.
Why it matters to a small business: Pillar One's failure to launch means the largest digital companies operating in your market may still pay disproportionately little tax in the countries where they actually earn, preserving their structural advantage over you.