Progress on pillar two stalls, while the European Parliament makes a breakthrough in agreeing revisions to some of its climate change proposals, reports Tim Sarson (KPMG).
BEPS 2.0: pillar one
On 11 July 2022 the OECD released its Progress report on Amount A of pillar one. The report is a consultation document issued for the purposes of obtaining further input from stakeholders on the technical design of Amount A which is the mechanism for allocating profits according to a formula based on local revenues.
The report includes a form of domestic model rules which contain new details for stakeholders for example on elimination of double taxation and the marketing and distribution safe harbour. There are also new (and complicated) rules on segmentation.
Many gaps still remain; the report does not yet include rules on the administration of the new taxing right including the tax certainty-related provisions which is expected before the Inclusive Framework meeting in October 2022.
The report makes...
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Progress on pillar two stalls, while the European Parliament makes a breakthrough in agreeing revisions to some of its climate change proposals, reports Tim Sarson (KPMG).
BEPS 2.0: pillar one
On 11 July 2022 the OECD released its Progress report on Amount A of pillar one. The report is a consultation document issued for the purposes of obtaining further input from stakeholders on the technical design of Amount A which is the mechanism for allocating profits according to a formula based on local revenues.
The report includes a form of domestic model rules which contain new details for stakeholders for example on elimination of double taxation and the marketing and distribution safe harbour. There are also new (and complicated) rules on segmentation.
Many gaps still remain; the report does not yet include rules on the administration of the new taxing right including the tax certainty-related provisions which is expected before the Inclusive Framework meeting in October 2022.
The report makes...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
