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 and the New York University School of Law.

The Organization for Economic Cooperation and Development is trying to rewrite...