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The three Ps of pillar one

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The draft OECD pillar one proposals are complex and deal with more difficulties and issues than any of us might individually imagine. The proposals envisage eleven building blocks: six for ‘amount A’ (allocating taxing rights to the market jurisdictions); two for ‘amount B’ (establishing fixed returns for marketing and distribution activities); two concerning procedures to achieve ‘tax certainty’; and a final building block covering implementation and administration. If pillar one is to be implemented, impacted groups have much to prepare for and little time to waste. However, with the US currently outside the process and complexities mounting, some might ask whether this whole journey is worth the effort.

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