MNE benefit RBAbr

Proposal for a Global Taxation System

– DAGTVA truth table –

DAGTVA® – Distribution of MNE profits

No. Problems exposed, requests, constraints and subjects Origin Pg Li Doc
94 Ap – Mt B – Fixed performance & reduce double taxation risks Pillar 1 15 46 RBAbr

QuoteAppendix – Detailed proposal on profit allocation

Amount B (RBAbg)

62. The second type of profit would seek to establish a fixed return (RBMbe) (or fixed returns, varying by industry or region) for certain “baseline” or routine marketing and distribution activities taking place in a market jurisdiction. The fixed return under Amount B would seek to reduce disputes in this area, where tensions are important as a result of applying the transfer pricing rules. The intention would be to benefit taxpayers and tax administrations, as it would reduce the risk of double taxation (RBAbr) as well as the substantial compliance costs arising from the aggressive enforcement of current transfer pricing rules.

With regard to the fight against double taxation, this subject is so important that it was dealt with in the RBQme section which refers to many other sections.

Although none of these pages in this study mentions the considerable reduction in compliance costs caused by a rigorous application of transfer pricing rules, you may note that the DAGTVA calculation of transfer prices is based on the slide show in reference where in slides 14 -16 -22, the exchanges between tax authorities with information already codified in the SAF-T protocol in version V2 developed by the OECD are free of charge.

This SAF-T protocol is already used by many countries in Europe including France with compliance costs which could be limited with the DAGTVA process.

All other tax information in the jurisdictions are not impacted by the DAGTVA transfer pricing calculation, except to record by automatic IT means, the exchanges concerning the WSTAX.

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