New link rule RLGnt

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
27a Guarantee a neutralité of treatment between the different business models Pillar 1 8 17 RLGnt

QuoteThe 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). This would be important to ensure neutrality between different business models (RLGnt), and capture all forms of remote involvement in the economy of a market jurisdiction.

As it is specified in the pages: RLSad, RLNac, RLPag, “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” .

As the taxation is applied on the transaction without prejudice of the quality of the MNE which sells and or buys, with DAGTVA, the neutrality of tax treatment is total, whatever the business model applied in each juridiction.

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