OECD Pillar I Comments Released

The Treasury Department announced it has published public comments received on the draft Organization for Economic Cooperation and Development/G20 Inclusive Framework Multilateral Convention to Implement Amount A of Pillar One and accompanying documents.

Pillar One aims to tax corporate profits to countries based on customer location, not the entity's legal domicile.

The request for public input was announced on October 11, following the Inclusive Framework’s Task Force on the Digital Economy’s release of the current draft text of the Pillar One MLC, the Explanatory Statement to the Pillar One MLC and the Understanding on the Application of Amount A Certainty.

The input request, which was open to all members of the public, closed on December 11. All comments are available for public review.

The three documents released on October 11 represent a years-long effort to find broad consensus among over 140 Inclusive Framework countries on a reallocation of taxing rights that better reflects the modern global economy. The release of the documents was the first time that a complete draft text of the Pillar One MLC documents had been made available to the public.

Treasury is now reviewing the comments as negotiations to finalize the Pillar One MLC documents continue among OECD/G20 Inclusive Framework members.