KPMG report: Comments on tax certainty aspects of Amount A under Pillar One

In response to the OECD request for comments, KPMG tax professionals submitted a memo with comments

In response to OECD request for comments, KPMG submitted a memo with comments

The Organisation for Economic Cooperation and Development (OECD) on 27 May 2022 issued a release seeking public comments on two consultation documents relating to tax certainty aspects of Amount A under Pillar One: Tax Certainty Framework for Amount A [PDF 808 KB] and Tax Certainty for Issues Related to Amount A [PDF 1.9 MB]—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 in the accompanying OECD release, a central element of Amount A is an innovative tax certainty framework that guarantees certainty for in-scope groups over all aspects of the new rules, including the elimination of double taxation. This would eliminate the risk of uncoordinated compliance activity in potentially every jurisdiction where a group has revenues, as well as a complex and time-consuming process to eliminate the resulting double taxation. The tax certainty framework incorporates a number of elements designed to address different potential risks posed by the new rules. Read TaxNewsFlash

In response to the OECD request for comments, KPMG tax professionals submitted a memo with comments [PDF 203 KB] on the OECD document Tax Certainty Framework for Amount A and a memo with comments [PDF 207 KB] on the OECD document Tax Certainty for Issues Related to Amount A.

Read all of KPMG’s comment letters to the OECD on BEPS.

 

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.