MNE benefit RBAps

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
85 Ap – principles of simplification for calculating profit. Pillar 1 14 42 RBAps

QuoteAppendix – Detailed proposal on profit allocation

Amount A (RBAag)

56. The completion of this step would not be intended to disturb the actual allocation of the remuneration derived from actual routine activities under the current transfer pricing framework. Instead, the purpose of the simplifying conventions would be merely to simplify the calculation of the deemed non-routine profit subject to the new taxing right (RBAps).

As specified in the RBMap section , the fact that there is no new tax right with DAGTVA also contributes to the simplification of the hoped-for international tax system, (related pages: RLSrl , PLSsy , RBAsm , RBAas).

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