Base erosion and profit shifting

Tax challenges of digitalisation: OECD invites public input on the draft rules for scope under Amount A of Pillar One


04/04/2022 – As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS 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 Draft Model Rules for Domestic Legislation on Scope under Amount A of Pillar One.


The purpose of the scope rules is to determine whether a Group will be in scope of Amount A. The rules are designed to ensure Amount A only applies to large and highly profitable Groups and have been drafted to apply in a quantitative manner, such that they are readily administrable and provide certainty as to whether a taxpayer is within scope. The Draft Rules for the Exclusions for Extractives and Regulated Financial Services will be released for public consultation at a later date.


The Inclusive Framework on BEPS has agreed to release this public consultation document (également disponible en françaisin order to obtain public comments, but the draft rules do not reflect consensus regarding the substance of the document. The stakeholder input received on the Draft Model Rules for Domestic Legislation on Scope will assist members of the Inclusive Framework on BEPS in further refining and finalising the relevant rules.


Interested parties are invited to send their written comments* no later than 20 April 2022. Instructions for submitting comments can be found in the consultation document.


Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at


For further information or inquiries, please contact [email protected].


*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.


UPDATE 05/04/2020 - The deadline has been extended from 18 April 2022 to 20 April 2022.