The OECD is consulting on Draft model rules for tax base determinations under amount A of pillar one. The draft rules will establish the profit (or loss) of an in-scope MNE that will be used for the amount A calculations to reallocate a portion of its profits to market jurisdictions. The rules determine that profit (or loss) will be calculated on the basis of the consolidated group financial accounts, while making a limited number of book-to-tax adjustments. The rules also include provisions for the carry-forward of losses.
The OECD/G20 Inclusive Framework on BEPS has agreed to release the public consultation document to obtain public comments, but the draft rules do not reflect consensus regarding the substance of the document. Stakeholder input received on the draft rules for tax base determinations will assist members of the Inclusive Framework in further refining and finalising the relevant rules.
The OECD is consulting on Draft model rules for tax base determinations under amount A of pillar one. The draft rules will establish the profit (or loss) of an in-scope MNE that will be used for the amount A calculations to reallocate a portion of its profits to market jurisdictions. The rules determine that profit (or loss) will be calculated on the basis of the consolidated group financial accounts, while making a limited number of book-to-tax adjustments. The rules also include provisions for the carry-forward of losses.
The OECD/G20 Inclusive Framework on BEPS has agreed to release the public consultation document to obtain public comments, but the draft rules do not reflect consensus regarding the substance of the document. Stakeholder input received on the draft rules for tax base determinations will assist members of the Inclusive Framework in further refining and finalising the relevant rules.
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