Base erosion and profit shifting

Tax challenges arising from digitalisation: Public comments received on the draft rules for tax base determinations under Amount A of Pillar One


08/03/2022 - On 18 February 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 invited public comments on the Draft Model Rules for Tax Base Determinations under Amount A of Pillar One to assist members in further refining and finalising the relevant rules.


The OECD is grateful to the commentators for their input and now publishes the public comments received.



For more information on the OECD’s public consultations in tax matters, visit


Enquiries should be addressed to [email protected].


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