EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.
Recent Searches
Implementation of the international tax reform agreement to ensure multinational enterprises pay a fair share of tax wherever they operate, is progressing.
On 11 July 2022, the Organization for Economic Co-operation and Development (OECD) Secretariat released a Progress Report on Amount A of Pillar One1 (the Progress Report), presenting a comprehensive draft of technical domestic model rules to implement a new taxing right under Amount A. Together with the Progress Report, the OECD released a Cover Note providing a revised schedule for the work on Amount A, Frequently Asked Questions on Amount A and a Fact Sheet providing an overview of the structure of the Amount A rules.
These documents provide significant new information with respect to the design of Pillar One Amount A and they also reflect a new timeline for its planned implementation. They make clear that the Amount A rules will not come into force in 2023 because further deliberation is merited with respect to a few of the building blocks. The Inclusive Framework is seeking written comments from stakeholders on the overall design of the Amount A rules, reflected in the Progress Report by mid-August 2022, with plans to review the input received and seek to stabilize the rules at the October Inclusive Framework meeting. When the Amount A rules are stabilized, they will be translated into provisions for inclusion in a Multilateral Convention (MLC), to be signed and ratified by Inclusive Framework members. The Inclusive Framework will then aim to finalize a new Multilateral Convention by mid-2023, for entry into force in 2024.
For a more in-depth analysis of the released documents, we refer to the EY Global Tax Alert.
In case of any further questions with regard to these developments, please do not hesitate to reach out to your trusted EY person of contact.
1 Amount A of Pillar One has been developed as part of the solution for addressing the tax challenges arising from the digitalisation of the economy. It 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.