Short-term Consultation On Pillar One's Framework For Tax Base Determination Rules

On 18 February 2022, the OECD Secretariat launched a short-term consultation on the second building block on "Pillar One". This second building block relates to tax base determinations, and more specifically how to measure the profit that forms the basis of partial reallocation under the Amount A rules. The working document does not reflect the final views of the Inclusive Framework jurisdictions. Reactions to the consultation need to be submitted before 4 March 2022. The targeted entry into force of the Pillar One rules remains officially the beginning of 2023.

Background

For several years, the Inclusive Framework explored adapting the international tax rules to an increasingly digitalised economy. On 8 October 2021, almost all members of the OECD/G20 Inclusive Framework agreed on certain key parameters to reallocate some taxing rights to market jurisdictions ("Pillar One") and to introduce a global minimum effective taxation ("Pillar Two"). The 8 October 2021