By Julie Martin, MNE Tax
The OECD today released more than 250 comment letters in response to a request for public feedback on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint.
Included are letters authored by large multinationals, like Amazon and Microsoft; trade associations such as BIAC and Keidanren; and NGOs, including the BEPS Monitoring Group and Oxfam. Tax advisors, tax advisor trade groups, and academics also weighed in.
The comments respond to an October 12 request for stakeholder input by a 137-country coalition known as the Inclusive Framework on BEPS.
The Inclusive Framework, an OECD-led body, is trying to reach a common agreement on a new set of international tax rules for multinational groups. The goal is to devise rules that are better suited for new digital business models; however, the latest proposals go far beyond just affecting multinationals in the digital economy.
Under consideration by the Inclusive Framework is a pillar one proposal that would alter existing rules for allocating a multinational group’s profit and related taxing rights among nations so that more tax is owed in countries where the multinational’s customers reside. A pillar two proposal would provide for a minimum tax on multinational group profits to prevent tax avoidance.
The Inclusive Framework countries were unable to agree to a common set of rules and, on October 12, instead approved the blueprint reports. These reports describe some areas of general agreement and areas of disagreement among countries regarding the pillar one and pillar two proposals. Along with the release of the reports was a request for stakeholder feedback on a series of questions.
The pillar one and two reports will also become the subject of an OECD public consultation, to be held virtually January 14–15.
The comments can be downloaded at this link.
Julie Martin
Julie Martin is the founder of MNE Tax. She edits the publication and regularly contributes articles on new developments in cross-border business taxation.
Julie has worked as a tax journalist and editor for more than 13 years. Prior to that, she worked as an in-house tax attorney in New York. She also holds an LLM in taxation from New York University School of Law.
Julie can be reached at [email protected].
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