Published 11 July 2022
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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. The Progress Report on Amount A of Pillar One 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.
The Progress Report on Amount A of Pillar One is a consultation document released by the OECD Secretariat for the purpose 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. Interested parties were invited to send their comments no later than 19 August 2022. A public consultation meeting on Amount A of Pillar One will be held on 12 September 2022.