Overview of the Pillar 1 Proposed Tax Dispute Resolution Process
Pillar 1 of BEPS 2.0 is made up of two parts. One part, Amount A allocates a portion of deemed residual profits of certain in-scope multinational enterprises (MNE) to market jurisdictions. As a large number of jurisdictions could be eligible to receive Amount A in a particular case, it is possible that an MNE could get caught up in nexus and profit allocation disputes with many countries, potentially facing inconsistent application of rules. Pillar 1 proposes novel and complex rules for preventing and resolving disputes.
For more information on this please contact Philip McQueston or any member of our Tax team.
Date published: 11 February 2021