Base erosion and profit shifting

Tax challenges of digitalisation: OECD invites public input on the regulated financial services exclusion under Amount A of Pillar One


06/05/2022 – 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 Regulated Financial Services Exclusion under Amount A of Pillar One.


The Regulated Financial Services Exclusion will exclude from the scope of Amount A the revenues and profits from Regulated Financial Institutions. The defining character of this sector is that it is subject to a unique form of regulation, in the form of capital adequacy requirements, that reflect the risks taken on and borne by the firm. The scope of the exclusion derives from that requirement, meaning that Entities that are subject to specific capital measures (and only those) are excluded from Amount A.


The Inclusive Framework on BEPS has agreed to release this public consultation document (également disponible en français) in order to obtain public comments, but it does not reflect consensus regarding the substance of the document. The stakeholder input received on the Regulated Financial Services Exclusion 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 May 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.