OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested
OECD seeking public comments on the draft model rules for domestic legislation on scope under Amount A of Pillar One
OECD seeking public comments on the draft model rules for domestic legislation
The Organisation for Economic Cooperation and Development (OECD) today issued a release seeking public comments on the draft model rules for domestic legislation on scope under Amount A of Pillar One—part of the ongoing work of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) in implementing the two-pillar solution to address the tax challenges arising from the digitalisation of the economy.
As explained by today’s OECD release:
- The purpose of the scope rules is to determine whether a multinational group will be in scope of Amount A.
- The rules are designed to provide that Amount A only applies to large and highly profitable multinational groups and have been drafted to apply in a quantitative manner, such that they are readily administrable and provide certainty as to whether a taxpayer is within scope.
- Draft rules for the exclusions for extractives and regulated financial services will be released for public consultation at a later date.
The OECD/G20 Inclusive Framework on BEPS agreed to the release of the public consultation document [PDF 424 KB], in order to solicit public comments, but as noted in today’s release, “…the draft rules do not reflect consensus regarding the substance of the document.” According to the OECD, the comments received on the draft rules will assist members of the Inclusive Framework in further refining and finalizing the relevant rules.
Comments are requested by 18 April 2022.
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