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.
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