Further Queries

Taxand welcomes the opportunity to provide comments on the Public Consultation Document: Secretariat Proposal for a “Unified Approach” under Pillar One published on 9 October 2019. We would like to share our thoughts, based on our experience in advising multinational enterprises. Understanding the challenges to arrive at a consensus position prior to the end of 2020, Taxand applauds the efforts made in this Public Consultation Document and aims to provide constructive commentary in furtherance of the mission.

 

The following comments have been made considering the principles for the Unified Approach under Pillar One (“UA”), which is focused on the allocation of taxing rights.  The current work was established in the Programme of Work adopted through the Inclusive Framework and endorsed by the G20 and seeks to identify the commonalities among the three alternatives set out in the Programme of Work under Pillar One, which are:

 

  • To reallocate taxing rights in favor of the user/market jurisdiction;
  • To envisage a new nexus rule that would not depend on physical presence;
  • Not to be based on the arm’s length principle and depart from the separate entity approach;
  • To look for simplicity, stabilization and to increase tax certainty.

Discover more: Comments on the Public Consultation Document: Secretariat Proposal for a “Unified Approach” under Pillar One published on 9 October 2019

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