KPMG report: Multilateral conventions on Amount A of Pillar One and Pillar Two subject to tax rule
Initial observations and analysis of both of the new multilateral conventions
Amount A of Pillar One and Pillar Two subject to tax rule
The Organisation for Economic Cooperation and Development (OECD) on 11 October 2023 released the text of a new Multilateral Convention to Implement Amount A of Pillar One [PDF 1.7 MB] that updates the international tax framework to co-ordinate a reallocation of taxing rights to market jurisdictions, improve tax certainty, and remove digital service taxes. Read TaxNewsFlash
The Multilateral Convention to Implement Amount A of Pillar One (MLC) was accompanied by an Explanatory Statement [PDF 5.2 MB], an Understanding on the Application of Certainty of Amount A [PDF 427 KB] and an Overview [PDF 1 MB].
The OECD on 3 October 2023 also released the new Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule, which includes an explanatory statement. Read TaxNewsFlash
Read an October 2023 report [PDF 405 KB] prepared by KPMG International that provides initial observations and analysis of both of the new multilateral conventions.
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