As published on transferpricingnews.com, Monday November 11, 2019.
The OECD is seeking stakeholders’ views on certain aspects of the Global Anti-Base Erosion (GloBE) Proposal to tackle digital economy tax challenges.
Earlier in May 2019, members of the Inclusive Framework on BEPS agreed a “Programme of Work” (comprising Pillar One and Pillar Two) for addressing the tax challenges posed by the digital economy.
The consultation document – issued on November 8, 2019 – focuses on specific technical issues in respect of the GloBE proposal (Pillar Two).
This Pillar focuses on the remaining BEPS issues and seeks to develop rules that would provide jurisdictions with a right to “tax back” where other jurisdictions have not exercised their primary taxing rights, or the payment is otherwise subject to low levels of effective taxation.
Comments are specifically invited on the following three technical design aspects of the GloBE proposal:
The use of financial accounts as a starting point for determining the tax base;
The extent to which an MNE can combine income and taxes from different sources in determining the effective (blended) tax rate on such income; and
Stakeholders’ experience with, and views on, carve-outs and thresholds that may be considered as part of the GloBE proposal.
The comments will assist members of the Inclusive Framework on BEPS in the development of a solution for its final report to the G-20 in 2020, the OECD said.
Comments must be received by December 2. A public consultation meeting will be held on December 9 at the OECD Boulogne in Boulogne-Billancourt.