UK and International Tax news

Public Consultation On Amount A Of Pillar One

Thursday 8th September 2022

The OECD will be holding a public meeting on Pillar One and Amount A on 12 September 2022.

Following the October 2021 statement made by the OECD on the two-pillar solution to address the tax challenges arising from the digitalisation of the economy, and subsequent issue of model rules, the OECD sought further responses from stakeholders through the issue of its Progress Report on Amount A of Pillar One in July 2022.

The Progress Report included a consolidated version of the operative provisions on Amount A, presented in the form of domestic model rules, which reflected the technical work completed to date. The report did not however include rules on the administration of the new taxing right, nor the tax certainty-related provisions, which are to be released before the next OECD Inclusive Framework meeting in October 2022.

Feedback from stakeholders on the overall design of the Amount A rules as well as specific building blocks before reaching final agreement was sought by 19 August 2022. The OECD is keen for the substance of these rules to be fully stabilised before the development and completion of a Multilateral Convention to be signed and ratified by the OECD Inclusive Framework members.

The OECD will be seeking public comments on the draft model rules at a public meeting which is to be held at 12 noon on Monday 12 September 2022 in Boulogne. The agenda will include discussions on the marketing and distribution profits safe harbour, the elimination of double taxation arising from Amount A and withholding taxes, and other selected topics including scope, revenue sourcing, tax base and unilateral measures.

The event will be open to the public and media and will also be live streamed and recorded.

For more information on the above, please contact Keith Rushen on 0207 486 2378.

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