Outcome Statement On OECD's Pillar One

On 11 July 2023, the OECD/G20 Inclusive Framework on BEPS agreed on an Outcome Statement about the two-pillar global tax reform. Regarding Pillar One, the OECD expects that the work on reallocating certain taxing rights to 'market' jurisdictions ('Amount A') and on simplifying transfer pricing for baseline marketing and distribution activities ('Amount B') should be completed by the end of 2023, opening then the phase for implementation in applicable legal instruments.

As regards timing, the main takeaways from this Statement are:

1. Amount A: The Multilateral Convention (MLC) was not yet published but should be finalized by the end of 2023 with the aim of enabling its entry into force in 2025.