New link rule RLSca

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 Ref.
21 New link rule link coupled with turnover threSholds (1). Pillar 1 3 35 RLSca

Quote : The new nexus could have thresholds (RLSca) including country specific sales thresholds…

P7 L29 Such discussion should also include consideration of size limitations (CALft), such as, for example, the €750 million revenue threshold used for country-by-country reporting requirements (CASch).

P8 L6 The simplest way of operating the new rule would be to define a revenue threshold (RLSca – RLSad) in the market.

As is also specified on the pages: CALft and CASch , with DAGTVA there is no longer a turnover threshold of 750 million EUR which could define a link rule or delimit the size of exporting companies, for the simple reason because the tax treatments of transactions take place on each of them and the notion of threshold then becomes irrelevant .

It is this transactional taxation that the OECD seems to favor.

There is no longer any declaration to be made country by country because each of them will have the number and the amount of each transaction carried out by an MNE. It will suffice to accumulate the data locally to apply the appropriate taxation to each MNE.

NOTE: Although this is not the subject of this page, it is also important to note that the export of a product sold can only be done by a company, whether multinational or not, unless the authorities taxation of both countries allow it .

The procedure would work like this:

Open  the slide show in reference.

    1. Authorization to continue the transaction ( slide 14 ), the exporting company must normally be registered with its tax authorities so that they give the export authorization in compliance with the agreements of the OECD article 7 ,
    2. When this authorization is given (1) , a copy for the first information is sent to the tax authorities of the market state for them to analyze the transaction which is put it in reserve.
    3. These should expect a purchase declaration (in B²B) which will occur on slide 15 ,
    4. Declaration of equality of controlled declarations in slide 16,
    5. Automatic exchange of BEPS information between the two States and production of export / import bar codes in slide 22 ,

(1) In a B²C transaction, it is this process which makes it possible to validate the bar codes of the import documents which will authorize this importation but above all it is this process which allows the market state to know of the transaction.

To conclude: We see that the concept of threshold of turnover by the company becomes useless with DAGTVA to be able to trade internationally, which favors the development of trade between States.

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