Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One – Two-Pillar Solution to the Tax Challenges of the Digitalisation of the Economy

Published 6 October 2022

Download the report (PDF)

About

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. One year after this agreement, and following the release and subsequent public consultation on the Progress Report on Amount A of Pillar One in July 2022, which included a consolidated version of the operative provisions on Amount A (presented in the form of domestic model rules), the OECD Secretariat has prepared the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One which includes the rules on the administration of the new taxing right, including the tax certainty-related provisions.

Public consultation

The Progress Report on the Administration and Tax Certainty Aspects of 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 administration and tax certainty aspects of Amount A. The comments provided will assist members of the Inclusive Framework in completing the work on those components. Interested parties are invited to send their comments on this discussion draft no later than Friday, 11 November 2022.

Access the call for input
Access the comments received (forthcoming)

Further information

Base erosion and profit shifting

Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One – Two-Pillar Solution to the Tax Challenges of the Digitalisation of the Economy