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Responses to amount A consultation

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The OECD has published the comments it received in response to its consultation on draft rules for calculating profits (or losses) of in-scope MNEs which will be used to determine the amount to be reallocated.

Respondents have commented on a wide variety of themes and, although the OECD has not yet collated or summarised those views, the following points are raised in a number of responses:

  • Loss carry-forward rules are essential and should include losses generated before the introduction of the rules. The proposed time limits for carry-forward should also be extended or, as proposed by some, should be unlimited.
  • Income relating to minority interests should be excluded from the group’s tax base for amount A purposes.
Issue: 1568
Categories: News