OECD: Comments on draft model rules for nexus and revenue sourcing under Pillar One Amount A

The intent of the rules is to source revenue to end-market jurisdictions where goods or services are used or consumed.

Nexus and revenue sourcing under Pillar One Amount A

The Organisation for Economic Cooperation and Development (OECD) released comments received on the Draft Rules for Nexus and Revenue Sourcing under Pillar One Amount A

Download comments (Zip file, 18MB – Note: This is a very large file; open from a desktop computer.)

Following the political agreement reached in October 2021 regarding a two-pillar solution to address the tax challenges arising from the digitalization of the economy by 137 members of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS), the OECD announced in December 2021 a schedule for public consultations on various aspects of its two-pillar plan to address the tax challenges arising from digitalization and globalization of the economy.

The OECD on 4 February 2022 launched the public consultation by releasing for public comment the draft rules for nexus and revenue sourcing. Read TaxNewsFlash

The public consultation document is structured as a general legislative article that articulates the nexus rules and the sourcing principles at a high level, followed by a schedule that sets out detailed rules for assigning each specified category of revenue to market jurisdictions. The intent of the rules is to source revenue to end-market jurisdictions where goods or services are used or consumed. Both the general article as well as the schedule are intended to be binding on implementing jurisdictions. Read a February 2022 report [PDF 1.8 MB] prepared by KPMG LLP that examines the draft model rules for nexus and revenue sourcing

 

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