– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|93||Ap – Mt B – fixed return to be evaluated at the level of profitability.||Pillar 1||15||41||RBMbe|
Quote : Appendix – Detailed proposal on profit allocation
Amount B (RBAbg)
62. The second type of profit would seek to establish a fixed return (RBMbe) (or fixed returns, varying by industry or region) for certain “baseline” or routine marketing and distribution activities taking place in a market jurisdiction. The fixed return under Amount B would seek to reduce disputes in this area, where tensions are important as a result of applying the transfer pricing rules. The intention would be to benefit taxpayers and tax administrations, as it would reduce the risk of double taxation (RBAbr) as well as the substantial compliance costs arising from the aggressive enforcement of current transfer pricing rules.
See the previous RBAbg page and all related topics.