Global Tax Wars: How New International Tax Rules Are Affecting Big Tech and SMEs

The Shifting Sands of Global Taxation

The phrase “Global Tax Wars” aptly captures the escalating tensions and fundamental overhaul currently reshaping international taxation. For decades, multinational enterprises (MNEs) have skillfully navigated and exploited the intricacies of a complex and often outdated global tax system to minimize their tax liabilities. This practice, while often legal, has frequently sparked public outrage and significant frustration among governments worldwide, leading to a new, more assertive pursuit of tax fairness and revenue by nations. This era is now giving way to a concerted effort to redefine the rules of engagement in the global economy.  

The international corporate tax system, largely a relic from the early 20th century, was conceived for an economic reality vastly different from today’s. It was designed at a time when physical presence predominantly dictated taxing rights, and cross-border transactions were simpler. This antiquated framework has proven woefully inadequate for the complexities of modern global business, particularly the burgeoning digital economy. Its inherent flaws have allowed MNEs to exploit loopholes, mismatches, and ambiguities in international tax rules, enabling them to shift profits to low- or no-tax jurisdictions. This strategic maneuver has significantly eroded national tax bases, depriving governments of crucial revenues needed for public services and infrastructure. The challenges have drastically intensified with the global integration of business, the increased international trade in hard-to-price services and intangibles, and the rapid growth of the digital economy.  

In response to this systemic challenge, the Organisation for Economic Co-operation and Development (OECD) and G20 nations initiated the Base Erosion and Profit Shifting (BEPS) project. This ambitious undertaking culminated in the Two-Pillar Solution, a framework designed to fundamentally reshape how and where MNEs are taxed globally. This comprehensive reform package is poised to impact companies of all sizes, albeit in distinct ways, setting the stage for a new chapter in international tax cooperation and competition.  

The current global tax landscape is undergoing a systemic reckoning. The core issue lies in the fundamental mismatch between a century-old tax framework, which primarily relies on physical presence to determine taxing rights, and the realities of a rapidly globalized and digitalized economy. In this new economic paradigm, value is increasingly created remotely and through intangible assets, rendering the traditional physical nexus concept obsolete. This incompatibility is not a minor flaw but a foundational instability that necessitates drastic reform, rather than mere adjustments. The sheer scale of lost revenue, estimated to be between $500 billion and $600 billion annually due to tax havens alone, underscores the severity of the problem, making incremental changes insufficient to address the deep-seated issues.  

The Genesis of a Global Reckoning: Why Tax Reform Became Inevitable

The corporate income tax, in its modern form, is just over a century old, with the United States introducing its federal corporate income tax in 1909. The prevailing international tax framework, largely established in the early 20th century, treated multinational enterprises (MNEs) as a collection of separate legal entities operating across different host countries, each using separate accounting. Transactions between these entities were governed by the “arm’s-length principle” (ALP), which stipulated that intra-group transactions should be priced similarly to comparable transactions between unrelated parties. However, this principle proved increasingly vulnerable to manipulation, particularly with the proliferation of hard-to-price intangible assets and services. The difficulty in valuing intellectual property (IP) due to a lack of comparable transactions exacerbated opportunities for profit shifting and frustrated the effective application of the arm’s-length principle.  

The inherent weaknesses of this outdated system, combined with financial liberalization processes that gained momentum in the 1980s, created fertile ground for “Base Erosion and Profit Shifting” (BEPS). BEPS refers to corporate tax planning strategies where MNEs exploit gaps and mismatches in tax rules to shift profits from higher-tax jurisdictions to low or no-tax locations, often where there is little or no economic activity. This could involve mispricing intra-group transactions, creating artificial loans between affiliates to take advantage of interest deductibility, or strategically locating intangible assets in offshore financial centers. These practices have had a profound impact, costing governments an estimated $100 billion to $240 billion annually in lost corporate income tax revenue, or even as high as $500 billion to $600 billion when considering all forms of tax havens. This revenue loss contributed to a dramatic decline in average corporate tax rates, which effectively halved from 49% in 1985 to 24% today, signaling a “race to the bottom” among countries seeking to attract investment.  

The rapid growth of the digital economy further intensified these challenges, acting as a profound disruptor to the traditional tax framework. Digital businesses could generate substantial revenue in a country without establishing a physical presence, a concept that fundamentally challenged the century-old nexus rules. Policymakers observed that the “online customer or user is now considered by many as being a critical driving force behind the value of digital services.” Yet, the existing system struggled to capture and tax profits where this value was truly created, leading to a significant decoupling of economic activity from physical presence. This disconnect fueled calls for new international tax rules that would grant market countries the right to tax a portion of company profits, even in the absence of a physical establishment.  

Beyond the quantifiable loss of revenue, widespread BEPS practices, particularly those employed by highly visible multinational corporations, significantly eroded public trust in the fairness and integrity of national tax systems. This public dissatisfaction, exacerbated by widening income inequality and the lingering anger from taxpayer-funded bank bailouts after the 2008 financial crisis, transformed a technical tax issue into a pressing social and political demand for justice. The public’s demand for fairness became a critical force driving governments to seek decisive action.  

The digital economy did not merely present new challenges; it fundamentally broke the traditional nexus concept, which had underpinned international taxation for a century. The increasing sophistication of information and communications technology systems, including the internet, facilitated a surge in remote cross-jurisdictional sales, effectively decoupling economic and physical presence. This rendered the existing “arm’s-length principle” for transfer pricing of intangibles virtually unworkable, as intellectual property is both easy to shift across borders and hard to value due to a lack of comparables. This situation forced a complete re-evaluation of where value is created and, consequently, where profits should be taxed. The shift to market-based taxation, allowing countries to tax profits even without a physical presence, emerged as a logical, albeit revolutionary, response to this fundamental breakdown of the old system.  

Pillar One: Reallocating Taxing Rights in a Digital World

Pillar One represents a bold attempt to reallocate taxing rights in a world reshaped by digitalization. Its primary purpose is to ensure that a portion of the profits of the world’s largest and most profitable multinational enterprises (MNEs) are taxed in the jurisdictions where their customers are located, irrespective of physical presence. This framework specifically targets MNEs with global revenues exceeding €20 billion (approximately $22 billion) and a profitability margin greater than 10%. The aim is to align taxing rights more closely with the actual location of market activities and value creation, particularly in the consumer-facing and digitalized segments of the economy.  

The core mechanism of Pillar One is Amount A, which dictates the reallocation of 25% of an MNE’s “excess profit”—that is, profit exceeding 10% of its revenue—to eligible market jurisdictions. This represents a significant departure from the traditional arm’s-length principle, as it allows countries to tax a portion of profits based on where sales occur, rather than solely where assets or physical operations are located. The process for Amount A involves several key steps: first, determining the relevant group profit; second, allocating a portion of this excess profit to the market countries based on revenue generated there; and third, implementing mechanisms to eliminate any resulting double taxation.  

Complementing Amount A is Amount B, a more pragmatic component of Pillar One. Amount B aims to simplify and streamline the application of transfer pricing rules specifically for “baseline marketing and distribution activities”. Instead of requiring complex and resource-intensive arm’s-length analyses for these routine functions, Amount B provides a fixed return based on a global pricing matrix. This simplification is particularly beneficial for low-capacity jurisdictions that often struggle with a lack of local market comparables and frequent transfer pricing disputes related to distribution activities. As of February 2025, Amount B has been incorporated into the OECD Transfer Pricing Guidelines, allowing jurisdictions to adopt this simplified approach for fiscal years commencing on or after January 1, 2025.  

A crucial objective of Pillar One is to provide an alternative to the proliferation of unilateral Digital Services Taxes (DSTs) that many countries have imposed. These DSTs, often seen as discriminatory, primarily target large U.S. technology firms and are based on revenue rather than income. The Pillar One agreement includes a commitment for participating countries to repeal their existing DSTs and prohibits the allocation of profits under Pillar One for any country that retains or introduces such taxes. However, the continued imposition of DSTs by some countries, such as Canada, and the threat of retaliatory tariffs from the U.S. underscore the ongoing tensions and the risk of a global tax war if a multilateral consensus on Pillar One is not fully achieved.  

Pillar One’s success is highly contingent on a multilateral convention (MLC) and widespread adoption, especially by the United States, which accounts for a significant share of the MNEs affected by these rules. The ongoing delays and the U.S. withdrawal from certain aspects of the global tax deal reflect deep geopolitical tensions and the formidable challenge of achieving consensus when national revenue interests and competitive advantages are at stake. This situation renders the full implementation of Pillar One highly uncertain and prone to fragmentation. The reliance on a multilateral agreement, particularly with a major economy like the U.S. wavering, highlights that Pillar One is not merely a technical tax reform but a complex geopolitical negotiation. The uncertainty and fragmented global tax landscape are direct consequences of this political friction, demonstrating that even well-designed technical solutions can falter without sustained political will.  

In contrast to Amount A, which represents a radical shift in taxing rights, Amount B is a more pragmatic and evolutionary step aimed at simplifying existing transfer pricing rules. Its incorporation into the OECD Transfer Pricing Guidelines suggests a greater likelihood of widespread adoption compared to Amount A. This is because Amount B addresses practical pain points, such as reducing disputes and compliance costs for low-capacity jurisdictions, rather than fundamentally reallocating large profit pools. This focus on simplifying existing rules and addressing administrative burdens makes Amount B less politically contentious and more appealing for immediate implementation, suggesting a higher probability of success and a more immediate, tangible impact on day-to-day tax operations for a broader range of MNEs.  

Table 1: Key Differences: OECD Pillar One vs. Pillar Two

Pillar Two: The Global Minimum Tax and its Far-Reaching Net

Pillar Two introduces a groundbreaking global minimum effective corporate income tax rate of 15% for large multinational enterprises. This agreement, adopted by more than 140 countries, aims to curb the decades-long “race to the bottom” in corporate tax rates and significantly reduce incentives for profit shifting to low-tax jurisdictions. It ensures that MNEs pay at least this minimum rate wherever they operate, irrespective of local tax incentives or preferential regimes. The OECD expects Pillar Two to generate substantial global revenue gains, estimated at around USD 220 billion annually, a significant increase from earlier projections.  

Pillar Two operates through a set of interlocking rules, collectively known as the Global Anti-Base Erosion (GloBE) rules:

• Income Inclusion Rule (IIR): This is the primary mechanism. It allows the ultimate parent entity’s jurisdiction to impose a “top-up tax” on the low-taxed income of its foreign subsidiaries, bringing the effective tax rate up to the 15% minimum. This acts as a top-down approach to ensure minimum taxation.  
• Undertaxed Payments Rule (UTPR): Serving as a backstop, the UTPR applies if the IIR does not fully capture the top-up tax (e.g., if the parent entity is in a non-implementing jurisdiction). It works by denying deductions or requiring an adjustment for certain payments made by a group entity in an implementing jurisdiction, ensuring the 15% minimum is met.  
• Qualified Domestic Minimum Top-up Tax (QDMTT): This is an optional domestic tax that allows a low-tax jurisdiction to collect the top-up tax itself, rather than letting another country (via IIR or UTPR) collect it. This mechanism incentivizes jurisdictions to raise their effective tax rates to 15% domestically, ensuring that the additional tax revenue remains within their borders.  

The implementation of Pillar Two rules has progressed rapidly across the globe. The IIR and QDMTT generally became effective in many implementing jurisdictions from January 1, 2024. The UTPR is typically scheduled to take effect from January 1, 2025. As of early 2025, over 50 jurisdictions worldwide have already enacted Pillar Two legislation, with many more countries indicating their intention to follow suit. The OECD continues to release administrative guidance to clarify the complex rules and facilitate consistent implementation across diverse tax systems.  

Pillar Two doesn’t just establish a minimum rate; it fundamentally redefines how tax revenue is collected from low-taxed profits. The QDMTT, in particular, transforms the “top-up” from a potential foreign imposition (via IIR or UTPR) into a domestic revenue-generating opportunity for jurisdictions that previously offered low rates. This creates a strong incentive for countries to adjust their own tax policies to capture this revenue, rather than allowing it to be collected by another jurisdiction. For instance, a country that previously attracted investment with a 10% corporate tax rate might now implement a QDMTT to bring the effective rate up to 15%, ensuring the additional 5% stays within its borders rather than being claimed by the parent company’s home country. This dynamic encourages a domestic realignment of tax policies to maximize national revenue under the new global framework.  

While Pillar Two aims to increase global corporate income tax revenue by hundreds of billions of dollars, the immediate and significant impact for many MNEs, especially in the initial years, is less about higher tax bills and more about the astronomical compliance costs. The complexity of calculating effective tax rates jurisdiction-by-jurisdiction, gathering granular data from disparate systems, and overhauling existing IT infrastructure often means that the cost of complying with Pillar Two exceeds any additional tax liability. For example, a survey found that 70% of respondents expected to spend $500,000 or more annually on Pillar Two compliance, with 25% anticipating over $1 million, while only 53% expected higher taxes. This demonstrates that the process of taxation itself becomes a significant financial burden, diverting substantial resources from core business activities and innovation.  

Table 2: Global Minimum Tax (Pillar Two) Implementation Status (Key Jurisdictions)

Note: This table provides a snapshot of the implementation status as of early 2025, based on the provided information. The landscape is continuously evolving.

Big Tech’s New Reality: Adapting to Higher Tax Burdens

Big Tech companies, characterized by their high profitability, global reach, and significant reliance on intangible assets, are squarely in the crosshairs of the new international tax rules. Both Pillar One and Pillar Two are designed to increase their tax liabilities by reallocating profits to market jurisdictions and ensuring that low-taxed income is subjected to the 15% global minimum. This fundamentally reduces the attractiveness of traditional profit-shifting strategies that historically relied on locating intellectual property (IP) in low-tax havens. Digital companies, which previously paid an average effective tax rate of only 9.5% compared to 23.2% for traditional businesses, are now facing a significant shift in their tax burden.  

To adapt to this evolving landscape, Big Tech firms are rethinking their global operational models. This includes a necessary revision of their IP holding structures, moving away from arrangements driven purely by tax benefits towards locations that demonstrate genuine economic substance, with real employees, offices, and business operations. There is also an observable trend towards “reshoring” or “nearshoring” operations, bringing them closer to key markets. This shift is driven by a desire to optimize tax efficiency under the new rules, enhance supply chain resilience, and improve regulatory compliance, rather than solely by tax considerations. Furthermore, domestic tax changes, such as the U.S. Section 174 rule, have profoundly impacted tech companies. This rule, which came into effect in 2022, mandates the amortization of research and development (R&D) expenses over five years for domestic R&D and fifteen years for international R&D, instead of allowing immediate deduction. This change significantly impacts tech companies’ cash flow and investment in product development, as expenses that once reduced taxable income in year one now must be spread out, leading to unexpected tax bills on “imaginary gains” and contributing to widespread layoffs across the sector, including at major players like Microsoft, Meta, Amazon, and Salesforce.  

The new rules impose an unprecedented compliance burden on Big Tech. These companies must now collect and process vast amounts of granular, often non-financial, data across multiple jurisdictions, frequently from disparate and unintegrated systems. This necessitates complex calculations to determine effective tax rates and top-up taxes for each jurisdiction. Such a monumental task requires significant investment in new tax technology, substantial upgrades to existing IT infrastructure, and enhanced cross-functional coordination between tax, finance, accounting, and IT departments to ensure data accuracy and traceability.  

The “Global Tax Wars” extend beyond mere tax numbers; they are fundamentally reshaping Big Tech’s core business strategies, particularly in R&D and workforce planning. The U.S. Section 174 change serves as a stark illustration of how a seemingly technical tax amendment can have profound, immediate consequences on a company’s ability to invest in innovation and directly lead to mass layoffs. Companies that previously structured their growth models around aggressive R&D expensing to keep taxable income near zero suddenly faced real tax bills on paper profits when those expenses had to be amortized. This demonstrates that tax policy is a powerful lever affecting economic growth and employment, influencing operational decisions and even triggering significant workforce reductions, far beyond simple tax avoidance.  

The sheer volume and complexity of data required for Pillar Two compliance elevate tax technology and robust data governance from a departmental concern to a strategic business imperative for Big Tech. Manual processes are simply unsustainable given the need for continuous, granular data collection from across the organization. Failure to invest in integrated, automated solutions risks not only non-compliance and disputes but also a significant drain on highly skilled resources. This shift from reactive compliance to proactive data management and technological integration becomes critical not just for avoiding penalties but for freeing up tax professionals for strategic analysis and risk mitigation in a rapidly changing tax landscape.  

SMEs in the Crossfire: Navigating Indirect Impacts and Opportunities

While the OECD’s Two-Pillar Solution primarily targets large multinational enterprises (MNEs) with global revenues exceeding €750 million for Pillar Two or €20 billion for Pillar One, most small and medium-sized enterprises (SMEs) generally fall outside these direct thresholds. This means they are typically not subject to the immediate top-up taxes or the complex profit reallocation rules of Pillar One.  

Despite not being directly in scope, SMEs engaged in cross-border activities face significant indirect impacts, particularly an increased compliance burden. The overall rise in international tax complexity, driven by the BEPS reforms and the global push for greater transparency, means that even smaller firms encounter higher costs for tax compliance. This disproportionately affects SMEs compared to larger corporations, as they often lack the internal resources, specialized tax departments, and sophisticated systems to navigate evolving regulations. For instance, per-employee tax compliance costs were found to be 90% higher for businesses with fewer than 50 employees compared to those with 100 or more. The overall increase in complexity within the global tax system, driven by BEPS 2.0, creates a “trickle-down” effect. This manifests as higher compliance costs for all businesses engaged in cross-border activities, as tax authorities become more sophisticated, leveraging advanced data analytics and automation tools, and demanding greater transparency. This forces even smaller firms to invest in more robust tax governance and data management, regardless of their direct Pillar Two obligations.  

The impact on SMEs’ competitiveness is multifaceted. On one hand, by curbing aggressive tax planning by large MNEs, the new rules aim to level the playing field, reducing the artificial competitive advantage previously enjoyed by companies that shifted profits to low-tax jurisdictions. This could foster fairer competition for domestic businesses. On the other hand, the narrowing of tax rate differentials and the increased focus on economic substance could induce domestic businesses to relocate to larger countries with more significant markets, potentially undermining the attractiveness of smaller countries for international businesses.  

Recognizing the potential burden on smaller entities, the OECD framework includes some provisions that indirectly benefit them or provide temporary relief. For example, Pillar One’s Amount B, which simplifies transfer pricing for baseline marketing and distribution activities, is intended to reduce disputes and compliance costs for all taxpayers, including those not directly subject to Amount A. Additionally, the International Accounting Standards Board (IASB) has issued temporary exceptions for SMEs regarding accounting for deferred taxes related to Pillar Two, acknowledging that these entities need time to determine how to apply the complex principles and requirements.  

While BEPS 2.0 aims for fairness, its design, particularly the narrowing of tax rate differentials, could inadvertently concentrate economic activity and investment in larger, more populous countries. This “geopolitical gravity shift” could undermine the historical competitive advantage of smaller nations that relied on attractive tax incentives to draw foreign direct investment (FDI). If smaller nations become less attractive for FDI, their domestic SMEs, which often depend on a vibrant local economy and access to international partnerships, could face reduced growth opportunities. This represents a subtle, long-term geopolitical implication that indirectly affects smaller businesses by altering the broader economic environment in which they operate.  

Table 3: Impact of New Tax Rules: Big Tech vs. SMEs (Qualitative Summary)

Challenges, Controversies, and the Road Ahead

The implementation of the Two-Pillar Solution is proving to be an immensely challenging undertaking for businesses and tax authorities alike. Companies face daunting tasks in collecting and processing the vast amounts of granular, often non-financial, data required for Pillar Two calculations. This frequently necessitates significant overhauls of existing IT and financial systems, which were not designed for such detailed jurisdictional reporting. The sheer complexity and novelty of the rules, coupled with the ongoing issuance of administrative guidance from the OECD, also lead to varying interpretations across different jurisdictions. This lack of complete clarity and consistency increases the risk of miscompliance and potential tax disputes.  

A major source of controversy and uncertainty in the global tax landscape is the fluctuating stance of the United States. While many countries, particularly within the European Union, have proceeded with the implementation of Pillar Two, the U.S. has expressed strong opposition, especially under the Trump administration. On January 20, 2025, President Trump signed an executive order declaring that the OECD Global Tax Deal “has no force or effect” in the United States without Congressional approval. This effective withdrawal threatens the multilateral consensus, raises the risk of double taxation for U.S. multinationals, and could trigger retaliatory tariffs and trade tensions, potentially leading to a fragmented global tax landscape. The U.S. position reflects a broader tension between national sovereignty, economic competitiveness, and multilateral cooperation. The threat of retaliatory tariffs, such as those proposed against countries imposing Digital Services Taxes (DSTs) on U.S. firms, highlights how tax policy is increasingly becoming a tool of trade leverage and diplomatic power, rather than solely a matter of revenue collection. This geopolitical interplay could lead to a fragmentation of the global tax system into competing blocs, akin to a new “cold war” in international finance.  

The complexity and novelty of the new rules are widely expected to lead to a significant increase in international tax disputes. Businesses and tax authorities alike grapple with interpreting and applying the new frameworks, leading to disagreements over profit allocation, effective tax rates, and the intricate interaction with existing bilateral tax treaties. A survey indicated that 77% of respondents believe Pillar Two will lead to more tax disputes due to complexity, lack of clarity, and varying interpretations. This heightened risk of disputes underscores the critical need for robust dispute prevention and resolution mechanisms. Initiatives like the Mutual Agreement Procedure (MAP) and the International Compliance Assurance Programme (ICAP) are becoming increasingly vital to provide greater tax certainty and predictability for multinational enterprises. The stated goal of BEPS 2.0 is to enhance tax certainty and reduce disputes. However, the reality of its complex implementation and ongoing political disagreements is leading to the opposite: increased uncertainty and a surge in tax disputes. This paradox means businesses must not only comply with new rules but also proactively manage potential conflicts and invest in dispute resolution strategies, transforming tax planning into a form of risk management in an inherently unstable environment.  

Amidst the challenges and political fragmentation of the OECD-led efforts, there is a growing push, particularly from developing countries, for a more inclusive global tax governance framework under the auspices of the United Nations. Negotiations are currently underway for a UN Tax Convention, which aims to provide a truly multilateral process where all member states have an equal voice. This initiative seeks to address issues such as wealth taxes, illicit financial flows, and cross-border services taxes, which many developing nations feel have not been adequately addressed by the OECD-led Inclusive Framework, which they perceive as skewed towards the interests of a few wealthy countries. This movement represents a potential shift in the center of gravity for global tax rule-making, reflecting a desire for a more equitable and representative international tax system.  

A New Chapter in Global Taxation

The “Global Tax Wars” signify a profound and irreversible transformation of the international tax landscape. The OECD/G20 Two-Pillar Solution, despite its inherent complexities and significant political hurdles, has fundamentally challenged century-old tax norms. It aims to reallocate taxing rights and establish a global minimum corporate tax, thereby reshaping how multinational enterprises operate and how nations collect revenue in an increasingly digitalized and globalized economy. This is not merely an adjustment but a systemic re-architecture of global tax principles.

For Big Tech, the era of aggressive profit shifting to low-tax jurisdictions is rapidly drawing to a close. These companies face significantly higher tax liabilities as profits are reallocated to market jurisdictions and low-taxed income is subjected to a global minimum. This necessitates fundamental changes to their operational models, including a re-evaluation of IP structures to emphasize genuine economic substance over purely tax-driven arrangements. Furthermore, the immense data requirements and computational complexities of the new rules demand substantial investments in advanced tax technology and robust data governance frameworks. The focus for these giants shifts from tax minimization to ensuring compliance and demonstrating tangible economic presence.

For SMEs, while generally falling outside the direct scope of the Two-Pillar Solution’s high revenue thresholds, the indirect impacts are undeniable. The overall increase in international tax complexity and the global push for greater transparency translate into higher compliance costs for any SME engaged in cross-border activities. This burden is often disproportionately felt by smaller firms due to their limited internal resources. However, the leveling of the playing field, by curbing aggressive tax planning by larger MNEs, could also present opportunities for SMEs by reducing the artificial competitive advantages previously enjoyed by their larger rivals.

For all businesses, proactive engagement with evolving tax policy, strategic investment in tax technology, and the establishment of robust internal controls are no longer optional but essential for navigating this volatile new era. The landscape demands agility and continuous adaptation.

The “Global Tax Wars” are far from concluded. The path ahead is one of continued evolution, adaptation, and potential fragmentation, especially given the ongoing political disagreements, particularly from the United States, and the emergence of alternative global tax governance forums like the United Nations. Businesses must remain vigilant, continuously monitor policy developments, and strategically adapt their operations to thrive in this turbulent, yet increasingly transparent, global tax landscape. The battle for fair and effective taxation will continue to define international economic relations for years to come, demanding a delicate balance between national revenue needs, global cooperation, and competitive business environments.