G20: OECD published draft document on model rules for nexus and revenue sourcing under Pillar One for public consultation

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Description

OECD published draft document on model rules for nexus and revenue sourcing under Pillar One for public consultation

On 4 February 2022, the Secretariat of the Organisation for Economic Cooperation and Development (OECD) published a draft document on model rules for nexus and revenue under Pillar One for public consultation. The stakeholders are invited to submit their feedback and comments until 18 February 2022. The two-pillar solution aims to implement effective taxation of the digital economy. Pillar One addresses the tax rules and targets multinational enterprises (MNEs) with the threshold set at a global turnover of more than EUR 20 billion and a before tax profitability of 10%. To a certain extent, profit taxation rights are to be moved away from the MNEs physical location into the destination countries of its goods or services. The revenue sourcing rules outlined in the draft document are intended to be used to determine if a specific jurisdiction qualifies for profit reallocation under Amount A of Pillar One. Under the proposed rules, nexus in a specific market jurisdiction would be determined based on a specific type of revenue, e.g. services, intangible property, finished goods, government grants etc. The revenue sourcing rules provide a clear methodology and a set of indicators to be used in the market jurisdiction determination and for jurisdiction approximation for cases in which the necessary information is not available.

Original source

Scope

Policy Area
Taxation
Policy Instrument
Direct taxes including Digital Service Taxes
Regulated Economic Activity
cross-cutting
Implementation Level
bi- or plurilateral agreement
Government Branch
executive
Government Body
central government

Complete timeline of this policy change

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2021-07-01
adopted

On July 1, 2021, the OECD and G20 published a statement regarding their two-pillar solution as part…

2021-07-10
adopted

The G20 finance ministers and central bank governors issued a communique stating their agreement on…

2021-10-08
adopted

The 136 member jurisdictions of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftin…

2021-12-20
adopted

On 20 December 2021, the Organisation for Economic Co-operation and Development (OECD) published th…

2022-02-04
in consultation

On 4 February 2022, the Secretariat of the Organisation for Economic Cooperation and Development (O…

2022-02-18
processing consultation

On 18 February 2022, the public consultation on the draft document on model rules for nexus and rev…

2022-03-14
in consultation

The OECD opened a consultation on the Commentary to support the implementation of the Global Anti-B…

2022-04-11
processing consultation

The OECD closed a consultation on the Commentary to support the implementation of the Global Anti-B…

2022-12-20
in consultation

On 20 December 2022, the Organisation for Economic Co-operation and Development (OECD) opened a con…

2023-01-20
processing consultation

On 20 January 2023, the public consultation closes on the OECD document titled “Pillar One – Amount…

2023-07-11
adopted

On 11 July 2023, 138 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftin…

2023-10-03
adopted

On 3 October 2023, the OECD adopted the "Multilateral Convention to Facilitate the Implementation o…

2023-10-11
under deliberation

On 11 October 2023, the OECD/G20 Inclusive Framework adopted the Multilateral Convention to Impleme…