The OECD has published two consultation documents:
Tax certainty framework for amount A: which aims to provide certainty for in-scope groups over all aspects of the new rules, including the elimination of double taxation. The framework will include various reviews, including:
Scope Certainty Review: to provide out-of-scope groups with certainty that they are outside the rules for Amount A for a particular period.
Advance Certainty Review: to provide certainty over a group’s methodology for applying aspects of the new rules that are specific to Amount A.
Comprehensive Certainty Review: to provide an in-scope group with binding multilateral certainty over its application of all aspects of the new rules for a period that has ended, ‘building on the outcomes of any advance certainty applicable for the period’.
Tax certainty process for issues related to amount A: which aims to ensure that in-scope groups benefit from dispute prevention and resolution mechanisms to avoid double taxation due to issues related to Amount A (for example, transfer pricing and business profits disputes), in a ‘mandatory and binding manner’.
The OECD has published two consultation documents:
Tax certainty framework for amount A: which aims to provide certainty for in-scope groups over all aspects of the new rules, including the elimination of double taxation. The framework will include various reviews, including:
Scope Certainty Review: to provide out-of-scope groups with certainty that they are outside the rules for Amount A for a particular period.
Advance Certainty Review: to provide certainty over a group’s methodology for applying aspects of the new rules that are specific to Amount A.
Comprehensive Certainty Review: to provide an in-scope group with binding multilateral certainty over its application of all aspects of the new rules for a period that has ended, ‘building on the outcomes of any advance certainty applicable for the period’.
Tax certainty process for issues related to amount A: which aims to ensure that in-scope groups benefit from dispute prevention and resolution mechanisms to avoid double taxation due to issues related to Amount A (for example, transfer pricing and business profits disputes), in a ‘mandatory and binding manner’.
