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ARTICLE · 15 MARCH 2021

OECD'S Pillar One Blueprint: Tax Base Determinations

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As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of the residual profit of MNE groups that fall within its defined scope.

United StatesTax
Scott Stewart
Scott Stewart
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As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of the residual profit of MNE groups that fall within its defined scope. The tax base is therefore determined on the basis of the profits of a group (rather than on a separate entity basis), and it is necessary to start with consolidated group financial accounts.

Comment: As discussed in prior blog posts, the reliance on consolidated financial statements in computing Amount A is a novel concept. Many taxing authorities are likely to view reliance on consolidated financial statements as a departure from the arm's length standard, which typically looks to profits earned by individual legal entities as the basis for taxation.

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