The OECD released the public consultation documents on the Amount A - Tax Certainty Framework for Amount A and Tax Certainty for Issues Related to Amount A on 27 May 2022. Amount A of Pillar One introduces a new taxing right over a portion of the profit of large and highly profitable enterprises for jurisdictions in which goods or services are supplied or consumers are located. Comments on the consultation documents are due by 10 June 2022. This alert provides a short overview of the proposed approaches and some initial observations. These are the sixth and seventh in a series of public consultations, separate responses requested in relation to each, on the Pillar One Amount A Model Rules that the OECD is expected to release over the coming months, with very short comment periods, as part of a 'rolling consultation.'
International Tax and Treasury