– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
|No.||Problems exposed, requests, constraints and subjects||Origin||Pg||Li||Doc|
|73a||Ap – Amount A – Generalities.||Pillar 1||13||18||RBAag|
Quote : Appendix – Detailed proposal on profit allocation
Amount A (General)
To provide a simple answer about the « Amount A » option, it should be pointed out that this solution could only possibly be implemented on condition of knowing precisely the turnover performed which would be the justification. For the moment this is not the case and it is the first objective of the DAGTVA transfer pricing calculation to provide this information.
We can add what has already been specified in the RBMap section :
« There is therefore nothing to renegotiate in this area which is the responsibility of each sovereign State, there is no new right to impose the modification of the direct taxation, with the ease of having a majority international agreement accepted in this area and with the probable consent of United States, which has already legislated internally in this domain.