Base erosion and profit shifting

International tax reform: Multilateral Convention to Implement Amount A of Pillar One




A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan – the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy – to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Multilateral Convention to Implement Amount A of Pillar One (the MLC) is a key component of this plan that co-ordinates a reallocation of taxing rights to market jurisdictions with respect to a share of the profits of the largest and most profitable multinational enterprises operating in their markets, improves tax certainty and removes digital service taxes.

In October 2023, the Inclusive Framework’s Task Force on the Digital Economy approved the release of a text of the MLC, together with related materials. The text of the MLC, which is not yet open to signature, reflects the consensus achieved so far among members, with different views on a handful of specific items noted in footnotes by a small number of jurisdictions.



Text of the MLC


Explanatory Statement to the MLC

  • English - published 11 October 2023
  • Français (à venir)


Understanding on the Application of Certainty for Amount A of Pillar One

  • English - published 11 October 2023
  • Français (à venir)




  • English - updated 12 December 2023
  • Français - mis à jour le 12 décembre 2023



26 October 2023 at 15:30-17:00 CEST


In this webinar, OECD experts explored key aspects of the MLC:

  1. Applying Amount A rules
  2. Tax certainty framework for Amount A and related issues
  3. Removal and standstill of digital services taxes and relevant similar measures


Press release




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