– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|48||Applicables to both benefits and losses.||Pillar 1||9||05||RBAtb|
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).
With the transactional taxation, each jurisdiction will calculate very precisely the tax share of the entity of an MNE based on the business activity it has declared automatically in this juridiction.
With the transactional taxation, losses are taken into account as much as profits but, as is specified in several pages, with a count that will be done by and for each jurisdiction and not in a global manner.
See also RBPpi page for further details.