– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|46||Possible provisions – transfer pricing.||Pillar 1||8||50||RBPpt|
29. The new rules, taken together with existing transfer pricing rules (RBDpx – RBPpt), will need to deliver the agreed quantum of profit to market jurisdictions and do so in a way that is simple, avoids double taxation (RBPpi) – RBNdi), and significantly improves tax certainty (RBRsj – PLSju) relative to the current position. It is also important that the new rules are reconciled with existing rules. That is, the new rules should not create distortions and should be effectively applicable to both profits and losses (RBAtb).
As you will see in the new DAGTVA transfer pricing calculation, and in the slide show in reference, the transactional taxation not change the tax laws in each State and at no time it is impossible to see the possibility to have a double taxation. The DAGTVA process only do the dispatch and the return of a share indirect taxation by effecting a better distribution of production taxes in each jurisdiction of activity.