10
Oct
On 9 October 2019, the OECD published a proposed unified approach to reform profit allocation rules (Pillar One of its working plan to address the tax challenges arising from the digitalisation of the digital economy). This proposal builds up on prior publications earlier this year.
It suggests to apply new rules for recognising a taxable nexus with market/user jurisdictions and allocating to them part of the profits of customer-facing businesses, based on a three-tier profit allocation mechanism. Unlike previous proposals,...