MNE benefit RBAwj

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
89 Ap – distributed profits (ie w %) between the juridictions the eligible market. Pillar 1 15 28 RBAwj

QuoteAppendix – Detailed proposal on profit allocation

Amount A (RBAag)

60. The final step of the proposed approach would be to allocate the relevant portion of the deemed non-routine profit (w% in the above example) among the eligible market jurisdictions (RBAwj). This allocation should be based on a previously agreed allocation key, using variables such as sales. The selected variables would seek to approximate the appropriate profit due (RBAea) to the new taxing right.

As in the RBAmw section , with DAGTVA, MNEs will not be called upon for the reasons also given in RBMap among others.

If taxation in each jurisdiction is proportional to economic activity, there is no need to levy additional wealth from what MNEs have earned to bail out State finances, this is what DAGTVA proposes and which promotes international trade!

As we have seen that MNEs could not be called upon in this area, it will be the States which will do so with the new system of international aid allocated according to a possible transactional imbalance observed.

Back to the truth table