– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|59||Qe – possible use of regional segmentation or by branch of activity.||Pillar 1||9||44||RBQrb|
Quote : 2.5. Pending key questions
32. A number of the areas in which further work would be required are already covered by the Programme of Work. These include work on the possible use of business line or regional segmentation (RBQrb), issues and options in connection with the treatment of losses, and the challenges associated with the determination of the location of sales (RBQpt). Some of this work is already underway.
As specified in the previous page RBMcf , « With the taxation defined on a transactional system, the turnover achieved in each jurisdiction by an MNE would be recorded to the nearest cent, there would be no supposed activity of the local entity that would not be taxed. As is explained in several sections including the RBMbr page which said below: »
« With the precision of the transactional system and the DAGTVA transfer pricing calculation, the notion of a necessarily approximate fixed compensation has no justification , as explained in the previous section RBMap dedicated to the“Amount A” option. »
It can be add, DAGTVA takes into account all the activities wherever they are, there would be no segmentation or excluded sector in the scope of this global tax system, as explained in the RLPen, CASex pages.