MNE benefit RBIst

Proposal for a Global Taxation System

– DAGTVA truth table –

DAGTVA® – Distribution of MNE profits

No. Problems exposed, requests, constraints and subjects Origin Pg Li Doc
72a Illustration – the group X is a group of MNEs. Pillar 1 9 11 RBIst
  1. Illustration (RBIst)

All the situations shown in the illustrations on pages 13 & 14 are fully under control with the DAGTVA transfer pricing calculation as stipulated in the RBRfa section where:

« The enforcement of this right to tax profits has always posed a complicated tax problem related to intra-MNE billings and re-invoices, sometimes passing through multiple jurisdictions, so that the accounting results end up revealing only ridiculously taxable profits.

With DAGTVA this “accounting and fiscal noria” can no longer exist because at each stage of invoicing, which may be intra-MNEs, they will be instantly taxed, but virtualy, for indirect taxation with a possible payment of the totality of this, linked to the compliance with the WSTAX(1). With regard to direct taxation, the accumulation of data about indirect taxation gives the amount of profits in each jurisdiction. lt will be levied by the relevant tax authorities of each MNE entity and may be, as today, paid at regular moments. »

(1) Wayfair Sale Tax transformed into Wayfair State TAX – or: WSTAX.

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