Pillar One of the G20/OECD Two-Pillar Solution to address the tax chal-lenges arising from the digitalisation of the economy (commonly termed Base Ero-sion and Profit Shifting 2.0 or“BEPS 2.0”) is complex. This comp...Pillar One of the G20/OECD Two-Pillar Solution to address the tax chal-lenges arising from the digitalisation of the economy (commonly termed Base Ero-sion and Profit Shifting 2.0 or“BEPS 2.0”) is complex. This complexity is exacerbatedby having only two official languages of English and French for international treatiessuch as “the Multilateral Convention to Implement Amount A of Pillar One”(MLC).This article provides a diagrammatic overview of Pillar One's allocation mechanismin the hope of promoting better understanding of the mechanism of Amount A andencouraging academic discussion. As key elements of Amount A such as the Market-ing and Distribution Safe-harbour (MDSH) remain under negotiation at the time ofwriting and there are many details, the diagrams and numbers of this article are notmeant to be comprehensive but ilustrative.展开更多
文摘Pillar One of the G20/OECD Two-Pillar Solution to address the tax chal-lenges arising from the digitalisation of the economy (commonly termed Base Ero-sion and Profit Shifting 2.0 or“BEPS 2.0”) is complex. This complexity is exacerbatedby having only two official languages of English and French for international treatiessuch as “the Multilateral Convention to Implement Amount A of Pillar One”(MLC).This article provides a diagrammatic overview of Pillar One's allocation mechanismin the hope of promoting better understanding of the mechanism of Amount A andencouraging academic discussion. As key elements of Amount A such as the Market-ing and Distribution Safe-harbour (MDSH) remain under negotiation at the time ofwriting and there are many details, the diagrams and numbers of this article are notmeant to be comprehensive but ilustrative.
