Base erosion and profit shifting

Tax challenges of digitalisation: OECD invites public input on the Progress Report on Amount A of Pillar One


11/07/2022 - 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 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.


Nine months after this historic agreement, significant work and progress have been achieved on the development of the technical rules of the new taxing right (Amount A), including through the valuable inputs received during the rolling public consultation held on various building blocks of Amount A. To seek further feedback from stakeholders, and consistent with the revised schedule for completing the work on Amount A agreed by the Inclusive Framework, the OECD secretariat has prepared a Progress Report on Amount A of Pillar One which includes a consolidated version of the operative provisions on Amount A (presented in the form of domestic model rules), reflecting the technical work completed thus far. This report does not yet include the rules on the administration of the new taxing right, including the tax certainty-related provisions, which will be released in due course and before the Inclusive Framework meeting in October 2022.


Public consultation

The Progress Report on Amount A of Pillar One is a consultation document released by the OECD Secretariat for the purposes of obtaining further input from stakeholders on the technical design of Amount A. The comments provided will assist members of the Inclusive Framework in completing the work on the technical development of Amount A.


Comments are sought with respect to the rules 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, input will be most helpful where it explains the additional guidance that would be needed to apply the rules to the circumstances of a particular type of business, as well as input on whether anything is missing or incomplete in the rules.


Frequently asked questions, as well as a fact sheet, are available to provide an overview on the application of the rules.


Interested parties are invited to send comments* on this discussion draft no later than Friday, 19 August 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.


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.


Public consultation meeting

The public consultation meeting on Amount A of Pillar One will be held on 12 September 2022 in hybrid format. The objective is to provide external stakeholders with an opportunity to provide input on the ongoing work.