On Saturday 9 September, the G20 countries called on the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) to finalise the OECD agreement on the taxation of multinationals.
In their statement, they called for a rapid resolution of “the few pending issues relating to the Multilateral Convention with a view to preparing the MLC for signature in the second half of 2023 and completing the work on Amount B”, relating to the framework for a simplified and streamlined application of the arm’s length principle to in-country baseline marketing and distribution activities, to be completed by the end of 2023.
The Multilateral Convention, which allows jurisdictions to reallocate and exercise a domestic right to tax a defined portion of residual profits, was the subject of a declaration in July (see EUROPE 13221/23). It is part of a two-pillar reform of the taxation of multinationals. Pillar II has already been the subject of a directive at European level, but has yet to be implemented (see EUROPE 13212/17).
The G20 also asked the Global Forum on Transparency and Exchange of Information for Tax Purposes to establish an appropriate and coordinated timetable for the start of exchanges between jurisdictions covered by the Crypto-Asset Reporting Framework (CARF).
See the G20 declaration: https://aeur.eu/f/8hy (Original version in French by Anne Damiani)