New link rule RLPag

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.
27 Provisions Possible – applicable to groups Pillar 1 8 15 RLPag

Quote : The intention is that a revenue threshold would not only create nexus for business models involving remote selling to consumers, but would also apply to groups (RLPag) that sell in a market through a distributor (whether a related or non-related local entity). 

As specified on the RLSad , RLNac , DAGTVA is based on a transactional taxation model which by definition not take into account a turnover threshold, neither the specified activity, nor the volume of these transactions.

We cannot therefore say, with DAGTVA, that it is the turnover threshold that triggers the link which leads to the application of correct taxation. Therefore, the notion of application to a group or MNE has no object in a transactional model as described in this study.

It is not the business environment of an MNE that is subject to taxation with DAGTVA but the taxable transactions that define this taxation everywhere the MNE has its activities in each juridiction in each entity.

With DAGTVA, the concept of  VAT group disappears.

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