The final outcome of the OECD’s digital tax work is likely to include both a global minimum tax and rules that shift more of a corporation’s taxable profits to the jurisdiction where it’s selling goods and services, a Treasury official said.

The most likely proposal will incorporate “something motivated by marketing intangibles, but a little bit more in the formulaic direction,” Brian Jenn, deputy international tax counsel at the Treasury Department, said at an April 16 event sponsored by KPMG...