On 4 April 2022, the OECD released draft Model Rules for domestic legislation on the scope of Amount A of Pillar One. Comments to the draft Model Rules are due by 20 April 2022.
This is the third in a series of public consultations 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.' The first release covered the revenue sourcing and nexus rules, for which we prepared this short overview, and the second release covered the rules for tax base determinations, for which we prepared this short overview. The scope rules determine when a Group will be in scope of Amount A. The consultation document notes that the rules covering the scope exclusions for extractives and regulated financial services and the application of Amount A to a disclosed segment will be released at a later date.
This alert provides a short overview of the draft Model Rules and some initial observations.