Our Tax Committee continues active engagement with OECD on Pillar One (Allocation of Taxing Rights) and Pillar Two (Global Minimum Tax) components of the Project on addressing tax challenges arising from the digitalization of the economy. Our continued engagement focuses on practicality, administrability and stability as core principles for effective implementation of new model rules and guidance.
On Pillar One, our most recent submission on 19 August includes comments on the OECD Consultation document “Progress Report on Amount A of Pillar One”. These comments focus on withholding taxes, marketing and distribution safe harbors, elimination of double taxation, alignment of work on amounts A and B, scope exclusions and further comments on existing Pillar One building blocks. Our members will present views from our submission at the upcoming 12 September OECD consultation on the Pillar One Progress Report.
On Pillar Two, our Business Advisory Group (BAG) works with OECD to provide input into the work on the development of Pillar Two Implementation Framework and Administrative guidance including issues such as safe harbors, GLOBE information return, the peer review process for qualifying taxes and other implementation issues requiring clarification and guidance.
We highly value our continued engagement with the OECD and G20 Inclusive framework, including the Taskforce on the Digital Economy. We support the OECD and Inclusive Framework stated priorities in developing the legislative solutions that are efficient for taxpayers and tax administrations and preserve consistent and coordinated outcomes for MNEs that avoid the risk of double taxation while minimizing compliance costs. As we navigate this process, our Committee works to effectively synthesise the many different and valid views of our members into an overall consensus position. Given the breadth and diversity of our membership, in case of no consensus on any specific issue, we make clear in our public submissions that there are dissenting views and clarify these varying perspectives as relevant to the work. All of our positions on the OECD Pillars 1 and 2 work are made public and are available here.