MNE benefit RBMct

Proposal for a Global Taxation System

– DAGTVA truth table –

DAGTVA® – Distribution of MNE profits

DAGTVA® – Distribution of MNE profits

No. Problems exposed, requests, constraints and subjects Origin Pg Li Doc
102 Ap – Mt Cbenefit for amount A which gives entitlement to amount C. Pillar 1 16 25 RBMct

QuoteAppendix – Detailed proposal on profit allocation

Amount C – Generalities (RBAcg)

65. In relation to Amount C, it would also be important to ensure that the profit under Amount A could not (whether in whole or part) be duplicated in the market jurisdiction (RBMcb), for example based on an argument that some or all of the profit under Amount A is also in some way referable to the functional activity in the market jurisdiction which is rewarded by Amount C (RBMct). Further work on certain aspects of the detailed interaction of Amounts A and C would therefore be warranted.

Back to the truth table