New link rule RLNrl

Proposal for a Global Taxation System

DAGTVA truth table –

DAGTVA® – The linkage rules of the taxation system

No. Problems exposed, requests, constraints and subjects Origin Pg Li Doc
17b New link rule. Pillar 1 6 18 RLNrl

Quote : The Secretariat’s proposal is designed to respond to these challenges by creating a new taxing right. Therefore, and consistent with all the proposals that have been made, the Secretariat proposal includes a new nexus (RLNrl).

As explained on the previous page RLPph , the link rules must be established at the level of exchanges between tax authorities (see the slide show in reference slides 14-15-16-22). This is what is sought by the OECD in the BEPS conventions between States, but with the important difference of bringing these BEPS exchanges in the real time of international trade, when commercial transactions are created and not, a posteriori, on request of the tax authorities in an other juridiction.

Back to the truth table