OECD invites public input on the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One

As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One.

Background

Following years of intensive negotiations to update and fundamentally reform international tax rules, 137 members of the Inclusive Framework joined the Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy released in October 2021.

Following the release and subsequent public consultation on the Progress Report on Amount A of Pillar One in July 2022, which included a consolidated version of the operative provisions on Amount A (presented in the form of domestic model rules), the OECD Secretariat has now prepared the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One which includes the rules on the administration of the new taxing right, including the tax-certainty related provisions.

Public consultation

The Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One(également disponible en français) is a consultation document released by the OECD Secretariat for the purposes of obtaining further input from stakeholders on the administration and tax certainty aspects of Amount A. The comments provided will assist members of the Inclusive Framework in completing the work on these components.

Comments are sought with respect to the processes and rules contained in this document. Where relevant, input should refer to the relevant section of the rules. While comments are invited on any aspect of the rules and procedures, input will be most helpful where it explains the additional guidance that would be needed to improve the application of the rules and procedures, as well as input on whether anything is missing or incomplete.

Interested parties are invited to send their comments* on this discussion draft no later than Friday, 11 November 2022. Instructions for submitting comments can be found in the consultation document.

Further information

Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at https://oe.cd/bepsaction1.

Source : OECD, publications, 6/10/2022