IOTA contributes to the 3rd round of regional consultations on BEPS for Eurasia

Eugenijus Soldatkovas's picture
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On 26 January 2022, IOTA and OECD virtually co-hosted a Regional Consultation on BEPS for Eurasia addressing the tax challenges of digitalisation which provided updates on the progress made on the development of the measures under Pillar One and Two, as well as on the capacity-building and bespoke technical assistance programmes available to support the implementation of these measures.

This Regional Consultation has brought together 167 delegates from a total number of 35 jurisdictions.

At the Session concerning Pillar One, the OECD Secretariat provided an update on progress made on the negotiation of the text of a Multilateral Convention (MLC) through which jurisdictions will implement Amount A and on its Explanatory Statement, as well as on the design of the Model Rules (MR) for jurisdictions to implement domestically, if needed, to give effect to the MLC. The OECD Secretariat also provided an update on the work related to Amount B, which aims at simplifying the application of existing transfer pricing rules to baseline marketing and distribution activities, taking into account the needs of low-capacity countries.

This was followed by the session covering the latest information on Pillar Two. In this session, the OECD Secretariat provided an update on progress made on the development of the Model GloBE Rules, as well as its commentary, for the implementation of the global corporate minimum tax rate of 15% on a jurisdictional basis by means of an Income Inclusion Rule and an Undertaxed Payments Rule.  The session also covered the Subject to Tax Rule model treaty provision, a treaty-based rule that restores some source taxation rights, where these have been limited under a tax treaty and the income is subject to a low rate of tax in the treaty partner jurisdiction.

The last session of the meeting was devoted to the update on capacity-building programmes. The Detailed Implementation Plan agreed in conjunction with the Statement on a two-pillar solution to addressing the tax challenges arising from the digitalisation of the economy promises “bespoke technical assistance to support developing countries in all aspects of implementation”. This session provided participants with an overview of the plans for capacity-building support including multilateral training, new knowledge resources, bilateral support and the roll-out of induction programmes focussed on the implementation of Pillar One and Pillar Two.

The meeting was co-chaired by Mr. Eugenijus Soldatkovas of the IOTA Secretariat and Mr. Andrew Auerbach of the OECD Secretariat.

Presentations and other material from the Regional Consultation are available for registered IOTA website users on the event’s webpage.