Large multinational enterprises (MNEs) may want to follow the Organization for Economic Cooperation and Development (OECD)'s latest consultation on its two-pillar approach to address tax challenges from the digitalization of the economy. The OECD has now released a new consultation paper on its model rules for tax base determinations, as part of its proposal to ensure certain MNEs pay tax in countries where they have consumer-facing activities but do not have a physical presence. Specifically, the OECD is asking for feedback on draft model rules for calculating the profit (or loss) of certain MNEs that will be used to calculate "Amount A" of Pillar One. Affected parties are asked to provide comments on these rules by March 4, 2022.

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