– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|67||Qe – rules of relief double taxation in the « unified approach ».||Pillar 1||10||27||RBQrd|
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).
We have seen that in the three headings mentioned above, that double taxation was impossible with DAGTVA, whether in indirect and direct taxation. Conventional rules can be maintained but become useless until a field of application is found.
DAGTVA will still impose, by default, this system with a Value Added Taxation on multinational cross-border transactions, hence the proposal of a global taxation system (1). This does not mean that each jurisdiction will be obliged to abandon the direct and indirect taxation that it already applies,
Nothing changes at this level on what already exists. There would be, in the context of a global agreement on taxation, nothing to negotiate at the state level in this area of the project.
(1) – This is what will allow the United States to enter with the standardization of the WSTAX in the VAT system, without them having the obligation to modify the Constitution with an agreement that would have been impossible to find and without having to pronounce this word of « VAT » banned in the US!