Base erosion and profit shifting

Tax challenges of digitalisation: OECD invites public input on extractives exclusion under Amount A of Pillar One


14/04/2022 – 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 Extractives Exclusion under Amount A of Pillar One.


The Extractives Exclusion will exclude from the scope of Amount A the profits from Extractive Activities. The exclusion applies where a Group derives revenue from the exploitation of Extractive Products and the Group has carried out the relevant Exploration, Development or Extraction. This approach reflects the policy goal of excluding the economic rents generated from location-specific extractive resources that should only be taxed in the source jurisdiction, while not undermining the comprehensive scope by limiting the exclusion in respect of profits generated from activities taking place beyond the source jurisdiction, or later in the production and manufacturing chain.


The Inclusive Framework on BEPS has agreed to release this public consultation document (également disponible en françaisin order to obtain public comments, but it does not reflect consensus regarding the substance of the document. The stakeholder input received on the Extractives 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 29 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.