To print this article, all you need is to be registered or login on Mondaq.com. As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of the residual profit of MNE groups that fall within its defined scope. The tax base is therefore determined on the basis of the profits of a group (rather than on a separate entity basis), and it is necessary to start with consolidated group financial accounts. Comment: As discussed in prior blog posts, the reliance on consolidated financial statements in computing Amount A is a novel concept. Many taxing authorities are likely to view reliance