In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting published agreements to address tax challenges arising from the digitalization of the economy. The first solution (Pillar One) aims to limit the taxing rights of the source/market country regarding digital or remote activities in exchange for the right to tax a small portion of the excess profits of large profitable multinational enterprises. It has raised questions and concerns among members of the Group of 24 (G-24), particularly about the economic impact of implementing Pillar One in developing countries. Many developing countries fear that they could be subject to mandatory dispute resolution and conflict prevention rules to which they cannot comply. This paper provides G-24 policymakers with a critical stocktaking that could be useful to their countries in taking advantage of the opportunities and reducing potential negative impacts.