OECD Opens Public Consultation on Pillar 1 Amount A

Tax attorney Joshua Odintz spoke with Tax Notes about draft rules for nexus and revenue sharing under the Organization for Economic Cooperation and Development's (OECD) two-pillar global tax plan. The OECD opened for public consultation Amount A under Pillar 1 of the plan, which gives market countries the right to ensure companies pay tax on a portion of their residual profits earned from activities in those countries even if the companies lack a physical presence there. Mr. Odintz commented that the draft rules do not make profit allocation clear and likened the potential international wrangling over it to a wrestling match.

"When wrestling had cage matches, they put everyone in a cage, [and the] last person standing is the winner," he said. "In some respects, if it's a U.S. company, the U.S. government will be in a cage with many countries duking it out to protect the U.S. revenue base, and the same will be true of markets multinationals, so I view this as a very exciting sport, and maybe we can sell tickets for the speedy resolution."

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