– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|65||Qe – in a group of MNEs holding Mt A benefits.||Pillar 1||10||23||RBQdg|
Quote : 2.5. Pending key questions
Elimination of double taxation
36. Because the existing domestic and treaty provisions relieving double taxation apply to multinational enterprises on an individual entity and individual country basis (RBQdd), the implementation of the proposed approach would require the identification of the member(s) of an MNE group that should be treated as owning the taxable profit in such market jurisdictions under Amount A (RBQdg) (e.g. entity(ies) with high profitability, entity(ies) owning certain intellectual property (IP)). In particular, it will be important to explore to what extent identifying the relevant taxpayers and the relevant profit to be reallocated would allow existing mechanisms for eliminating double taxation (RBQme) to continue to operate effectively. This would involve how domestic and treaties rules to relieve double taxation could operate under the “unified approach” (RBQrd).
As is explained in many sections including: RBMap , RBMar , RBMaf, RBMag, RBMac, MNEs entities are perfectly identified in the DAGTVA calculation of transfer prices by their internal transactions, with a taxation which is distributed equally and based on local turnover where taxable profits in each jurisdiction under « Amount A » will be claimed.