– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|63||Qe – choice of the amount to be reallocated will ultimately be the result of a political agreement.||Pillar 1||10||14||RBQcm|
Quote : 2.5. Pending key questions
Definitions and quanta
35. Similarly, agreeing multilaterally on the scale or amount of profits reallocated to market jurisdictions (in particular Amount A) (RBQam) will be an essential aspect of the “Unified Approach”. The amount of profits to be reallocated would be determined by simplifying conventions and will be informed by an impact assessment of the “Unified Approach”. However, the choice of this amount will ultimately be the result of a political agreement that needs to be acceptable (RBQcm) to all members of the Inclusive Framework, small and large, developed and developing.
As is detailed among others arguments in the RBQam and RBMap sections, it is too early to want to negotiate amounts to reallocate until we know precisely the amounts in question and from which jurisdictions they come with an agreement impossible to find between 137 States which have divergent interests in this project, not to mention those which are not cooperative in this domain!
The priority of the political agreement must focus on the establishment of a simple system that provides a real knowledge of what should be taxed, by answering these questions: where, when, how, by whom and who should be taxed .
This is what the DAGTVA transfer pricing calculation proposes. There will always be time in other negotiations, after having carried out impact studies probably over several years, to see whether there is reason to rebalance international taxation again .