On March 4, 2019, TEI filed comments with the Organisation for Economic Co-Operation and Development (OECD) regarding the OECD’s public consultation document Addressing the Tax Challenges of the Digitalisation of the Economy (the Document). Despite the Document’s title, many of the proposals in the OECD consultation would impact all businesses and not just those that may be “heavily” digitalized. TEI’s comments focused on the practical difficulties of complying with the Document’s proposals to change the current OECD profit allocation and nexus rules. TEI comments also noted that many of the proposals depart from the arm’s length standard in their approach to taxing the income of associated enterprises and the need for final OECD guidance to ensure multinational enterprises have an avenue for relief from double taxation, among other things. TEI’s comments were prepared under the aegis of the Institute’s European Direct Tax Committee, whose chair is Giles Parsons. Benjamin R. Shreck, TEI Tax Counsel, coordinated the production of TEI’s comments.