On 11 October 2023, the OECD/G20 Inclusive Framework adopted the Multilateral Convention to Implement Amount A of Pillar One (MLC). The MLC reflects the existing consensus of the members of the Inclusive Framework, which is aimed at addressing tax challenges resulting from globalisation and digitalisation. Amount A provides a taxing right to market jurisdictions on the basis of profitability rather than physical location of the largest multinationals. The MLC contains key definitions and rules for the implementation of Amount A in their currently agreed forms, including scope, tax computation and profit allocation rules, and safeguards to avoid double taxation. The Convention also contains rules regarding its ratification by members.
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