Draft Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One

As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One.

Following years of intensive negotiations to update and fundamentally reform international tax rules, 137 members of the Inclusive Framework joined the Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy released in October 2021.

Following the release and subsequent public consultation on the Progress Report on Amount A of Pillar One in July 2022, which included a consolidated version of the operative provisions on Amount A (presented in the form of domestic model rules), the OECD Secretariat has now prepared the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One which includes the rules on the administration of the new taxing right, including the tax-certainty related provisions.

Interested parties are invited to send their comments* on this discussion draft no later than Friday, 11 November 2022. Instructions for submitting comments can be found in the consultation document.

Comments are sought with respect to the processes and rules contained in this document. Where relevant, input should refer to the relevant section of the rules. While comments are invited on any aspect of the rules and procedures, input will be most helpful where it explains the additional guidance that would be needed to improve the application of the rules and procedures, as well as input on whether anything is missing or incomplete.

*Please note that all written comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting. Speakers and other participants at the upcoming public consultation meeting will be selected from among those providing timely written comments.

The proposals included in this consultation document have been prepared by the OECD Secretariat, and do not represent the consensus views of the Inclusive Framework, the Committee on Fiscal Affairs or their subsidiary bodies.

Published 16 November 2022

The OECD is grateful to the commentators for their input and now publishes the public comments received.

• Download the comments (Zip file, 10MB - Please open from a desktop computer)

Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at https://oe.cd/bepsaction1.

For further information or inquiries, please contact tfde@oecd.org.