The official, David Bradbury, said during a webinar that while the group leading nearly 140 jurisdictions aimed for an agreement on both the reallocation of taxing rights and a minimum tax this year, some items would need further discussion into 2021.
"We are moving ahead at full speed," said Bradbury, head of the tax policy and statistics division in the OECD's Center for Tax Policy and Administration.
Progress has been made, Bradbury added, and while the group is still trying to deliver an agreement by year's end as mandated by the Group of 20 leading rich and developing nations, "of course, there will be some elements that will need ongoing discussion going into the new year."
Bradbury's comments echo those made in early May by Pascal Saint-Amans, the OECD tax chief who is leading the negotiations. Bradbury told Law360 that the OECD's message hasn't changed.
Meanwhile, German economist Dominika Langenmayr of the Catholic University of Eichstätt-Ingolstadt warned on the webinar that some changes the OECD is pursuing, though worthwhile, might not be as revolutionary as they are sometimes perceived.
If countries were able to raise the tax burden for companies, those companies might simply charge more to website users, consumers or workers, Langenmayr said. For example, Amazon.com passed the cost of France's digital tax onto users of its marketplace in that country.
"We sometimes read that Europe could gain by finally taxing these U.S. [companies] more," she said. "But there's no free lunch for anyone. If we tax these firms more, some burden will be borne by workers, shareholders."
Langenmayr also raised the question of whether countries that export more than they import would lose under a system that shifts taxing rights to countries with a large body of consumers, which tend to buy imported goods.
OECD officials taking part in the webinar gently pushed back on this theory, suggesting that it wasn't a major concern.
"I would caution against people jumping to conclusions about what countries win or lose based on what their current account position is," Bradbury said, referring to a broad measure of a country's export or import position.
Another OECD official, Martin Kreienbaum, who also works in Germany's Finance Ministry, said that even though Germany is an exporting country, the point of the tax reform isn't the reallocation of taxing rights but rather the avoidance of double taxation.
This requires "broad international consensus," he said.
"That is the main purpose; it's not the question of winning or losing … it is leveling the playing field and making sure that taxpayers don't pay twice," Kreienbaum said.
--Editing by Neil Cohen.
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