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OECD's Pillar One Blueprint: Profit Allocation - Tax

To print this article, all you need is to be registered or login on Mondaq.com. Overview. As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of residual profit of MNE groups that fall within its defined scope. The calculation and allocation of Amount A will be determined through a formula that is not based on the Arms Length Principle (ALP). The formula will apply to the tax base of a group (or segment where relevant) and will involve ...
Automated Digital Services Length Principle Consumer Facing Business Pillar One Arm Amp 39s Length Standard Profit Allocation
Source: mondaq.com

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