The OECD has published the comments it received in response to its consultation on draft rules for calculating profits (or losses) of in-scope MNEs which will be used to determine the amount to be reallocated.
Respondents have commented on a wide variety of themes and, although the OECD has not yet collated or summarised those views, the following points are raised in a number of responses:
Loss carry-forward rules are essential and should include losses generated before the introduction of the rules. The proposed time limits for carry-forward should also be extended or, as proposed by some, should be unlimited.
Income relating to minority interests should be excluded from the group’s tax base for amount A purposes.
The OECD has published the comments it received in response to its consultation on draft rules for calculating profits (or losses) of in-scope MNEs which will be used to determine the amount to be reallocated.
Respondents have commented on a wide variety of themes and, although the OECD has not yet collated or summarised those views, the following points are raised in a number of responses:
Loss carry-forward rules are essential and should include losses generated before the introduction of the rules. The proposed time limits for carry-forward should also be extended or, as proposed by some, should be unlimited.
Income relating to minority interests should be excluded from the group’s tax base for amount A purposes.
