Yesterday, the OECD issued an Outcome Statement on Pillars 1 & 2 that gives an update on the status and timeline for implementation of Amount A and B of Pillar One, and the Subject-to-Tax Rule (STTR).
Last Updated: 08/02/2024 Full Citations to Domestic Laws Links to Domestic Legislation Covers DSTs, Digital Withholding Taxes and Digital PEs Overview How to Use the
On December 20, 2022, the OECD opened a consultation on the draft Multilateral Convention provisions for the removal of Digital Services Taxes and other similar measures under Pillar One.
On October 6, 2022, the OECD issued the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One (the ‘Progress Report’), which includes draft Model Rules on the administration of Amount A.
Nigeria has rejected Pillar 1 and 2 on the basis that the thresholds would result in a loss of tax revenue. We look at the changes to domestic law to tax MNEs.
Whilst Pillar 1 and Pillar 2 are separate and independent of each other, there are areas where they overlap, most notably the inclusion of Pillar 1 tax for Pillar 2 purposes and the overlap in some of the adjusted profits definitions.
Our OECD Pillar One Modelling Tool is designed to provide an analysis of the high-level impact of Amount A of Pillar One.
The Amount A elimination of double taxation provisions in Title 5 of the Progress Report on Amount A of Pillar One apply to prevent a multinational group being taxed twice on profits allocated to a market jurisdiction where there is already some form or physical establishment that is subject to tax.
The Revenue Sourcing Rules for Amount A are used to determine where an in-scope multinational group derives its revenues. This is then used in the profit reallocation calculation.
Use our interactive tool to quickly determine the relevant sourcing rule for each revenue type.
The Amount A reliable indicators are the practical methods of allocating revenue to jurisdictions for the purposes of the Pillar One, Amount A revenue sourcing rules.
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