The OECD has entered into several rounds of public consultation on the framework and detailed mechanics of Pillar One. The overall aim of Pillar One is to reallocate profits of large multinational enterprises to the market jurisdiction in which they have substantial engagement, regardless of whether or not they have a physical presence there. Substantial engagement in a market jurisdiction is measured by a 'nexus test' which will be met if the MNE generates €1m of income in a year from a jurisdiction. Detailed revenue sourcing rules will need to be applied to determine the jurisdiction in which revenue is derived.
The table below lists the consultations carried out by the OECD to shape the rules needed to achieve the overall aims of Pillar One, together with links to respondents' comments:
Consultation document | Subject matter | Closing date | Public comments |
Pillar One — Amount B: appropriateness of the scope and pricing framework | Consideration of two alternatives to the scope of Amount B, plus the appropriateness of the pricing framework, the application to the wholesale |
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