If you had set your clocks for a deal to be reached at the OECD tax talks in October, you may need to push that back. https://news.bloombergtax.com/daily-tax-report-international/global-tax-reform-process-hangs-on-u-s-election-saint-amans

Most countries it would appear at thinking of pushing back an agreement on account of the U.S. election, which will mean negotiations would resume in March 2021, with an aim of reaching a deal by the end of that year. This would be "extremely difficult" according to the OECD

Why? well 9 months to negotiate, with either a new or reluctant US admin. At the same time as we are either in middle trade war or one was narrowly averted on the grounds a deal must be struck quickly.

What is happening with the OECD negotiations themselves, well here is a super interesting thread from @JohanLangerock: https://twitter.com/JohanLangerock/status/1277879610806603777

I will just add a couple thoughts: really interesting that the OECD is considering a formulaic carve out for preferential tax regimes. It could have a huge effect on what the effective minimum tax rate ultimately amounts to.

Interesting also that some countries are against the subject to tax rule altogether.

Final interesting point is that there is a battle over whether nexus should only apply to marketing intangibles and distribution related to excess profits or whether it should apply to all transfer pricing arrangements.