Tag: Unified Approach

OECD Pillar One framework proposing a single set of rules to reallocate taxing rights over MNE profits to market jurisdictions, combining elements of user participation, marketing intangibles, and significant economic presence theories. Disputes centre on nexus thresholds and profit allocation formulae.

OECD releases statement on support of the two pillar tax plan - joined by 130 countries

OECD releases statement on support of the two pillar tax plan – joined by 130 countries

A OECD statement has been issued where 130 countries and jurisdictions have agreed to join and support the two pillar plan. A small group of 9 countries have not yet joined the Statement. “The two-pillar package aims to ensure that large Multinational Enterprises (MNEs) pay tax where they operate and earn profits, while adding much-needed certainty and stability to the international tax system. Pillar One will ensure a fairer distribution of profits and taxing rights among countries with respect to the largest MNEs, including digital companies. It would re-allocate some taxing rights over MNEs from their home countries to the markets where they have business activities and earn profits, regardless of whether firms have a physical presence there. Pillar Two seeks to put a floor on competition over corporate income tax, through the introduction of a global minimum corporate tax rate that countries can use to protect their tax bases. The two-pillar package will provide much-needed support to governments needing ... Read more
G7 Support for OECD's proposal on a Global Tax Reform - Pillar I and II

G7 Support for OECD’s proposal on a Global Tax Reform – Pillar I and II

The G7 has agreed to back an international agreement on global tax reforms aimed at ending the reign of tax havens and have big international companies start paying their fair share of taxes. Under Pillar One of the reform, multinationals will be required to pay tax in the countries where they sell there products – and not just where they have their headquarters. The rules would apply to largest global firms with at least a 10% profit margin – and would see 20% of profit above the 10% margin reallocated and taxed in market countries. Under Pillar Two, a global minimum tax of 15% will be applied on corporate income on a country by country basis, creating a more level playing field.  – The G7 comprises of US, UK, Canada, France, Germany, Italy and Japan. EU and the heads of the IMF, World Bank Group, OECD and FSB – ... Read more
US response to OECDs Unified Approach

US response to OECDs Unified Approach

Letter from the US treasury to the OECD concerning the proposed Unified Approach on taxation of the Digital Economy, and the reply to the letter from the OECD ... Read more