'Amount A’ – OECD’s New Taxing Right and the Indicators for its Economic Nexus
One of the key cornerstones of the International Tax Architecture hitherto has been the notion of a Permanent Establishment (PE). However, the traditional concept of PE has been inadequate in addressing the tax challenges of the digitalization of the economy. Taking up the gauntlet, the Organisation for Economic Cooperation and Development (OECD) has unveiled the Outline of the Architecture of a Unified Approach on Pillar 11 on 29-30 Jan 2020. With this, it has become clear that Amount A is the primary responsibility of the International Tax community to the tax challenges posed by the digitalization of the economy. In the latest statement of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS IF), OECD has pledged to continue its work on the key policy features of a consensus-based solution to the Pillar One issues. To that effect, it has divided the program of work for the technical and policy issues under Pillar One into 11 workstreams. Among these, the second workstream is focused on the creation of new nexus rules and interactions with the existing treaty provisions.It is in this context that the essay analyses the inadequacy of the traditional concept of PE and discusses the concept of Amount A. Further, the essay focuses on the second workstream and proposes a number of indicators that could be factored into the new economic nexus for the Amount A of the ‘Unified Approach under Pillar One.’ “There is a consensus to build a solution by the end of 2020. Let’s be clear – either we have at the end of 2020 an international solution… clearly in the interest of all countries and digital companies, or there is no solution and … then it will be up (for) the national taxes to enter into force.” France’s Finance Minister, Bruno Le Maire at the sidelines of G20 Finance Ministers’ Meeting in Riyadh, Saudi Arabia, on 23 Feb 2020
Year of publication: |
[2021]
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Authors: | Naudiyal, Manoj |
Publisher: |
[S.l.] : SSRN |
Subject: | OECD-Staaten | OECD countries | Wirtschaftsindikator | Economic indicator |
Saved in:
freely available
Extent: | 1 Online-Ressource (17 p) |
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Type of publication: | Book / Working Paper |
Language: | English |
Notes: | In: National Law School Journal 2020 Nach Informationen von SSRN wurde die ursprüngliche Fassung des Dokuments 2020 erstellt |
Source: | ECONIS - Online Catalogue of the ZBW |
Persistent link: https://www.econbiz.de/10013323346
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