A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan – the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy – to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Multilateral Convention to Implement Amount A of Pillar One (the MLC) is a key component of this plan that co-ordinates a reallocation of taxing rights to market jurisdictions with respect to a share of the profits of the largest and most profitable multinational enterprises operating in their markets, improves tax certainty and removes digital service taxes.
In October 2023, the Inclusive Framework’s Task Force on the Digital Economy approved the release of a text of the MLC, together with related materials. The text of the MLC, which is not yet open to signature, reflects the consensus achieved so far among members, with different views on a handful of specific items noted in footnotes by a small number of jurisdictions.
Text of the MLC
Explanatory Statement to the MLC
Understanding on the Application of Certainty for Amount A of Pillar One
26 October 2023 at 15:30-17:00 CEST
In this webinar, OECD experts explored key aspects of the MLC: