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TREASURY SEEKS PUBLIC INPUT ON DRAFT OECD/G20 INCLUSIVE FRAMEWORK PILLAR ONE
MULTILATERAL CONVENTION TEXT


October 11, 2023

WASHINGTON – Today, the U.S. Department of the Treasury announced a request for
public input on the draft OECD/G20 Inclusive Framework Multilateral Convention
to Implement Amount A of Pillar One (Pillar One MLC) and accompanying
documents.  The Inclusive Framework’s Task Force on the Digital Economy released
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
(describing certain administration and dispute resolution parameters) following
intensive negotiations.  The three documents 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 Treasury Department considers the release of the draft Pillar One documents
a key step forward in the Pillar One negotiations. These documents reflect
countless hours of discussions, across multiple U.S. administrations, and among
hundreds of negotiators.  Treasury stands behind the negotiations, which have
resulted in many difficult compromises by all sides with respect to both the
design of the partial reallocation of taxing rights and the elimination of
discriminatory digital services taxes and similar measures,” said Assistant
Secretary for Tax Policy Lily Batchelder.  “However, as the cover note in the
documents states, Pillar One represents a uniquely significant reform to the
international tax system.  Because of the breadth and complexity of the changes
proposed, we view public input as critical to our process—to ensure
transparency, to facilitate the resolution of several remaining open issues, and
to hear whether the proposed framework would be workable for U.S. taxpayers and
other stakeholders.”

Pillar One is being negotiated as part of the OECD/G20 Inclusive Framework
Two-Pillar Solution to Address the Tax Challenges Arising from the
Digitalization of the Economy.  The Pillar One architecture is designed to
update the allocation of international taxing rights over a portion of the
profits of the largest and most profitable multinational corporations (“Amount
A”) and to provide greater tax certainty and stability on certain cross-border
transactions (“Amount B”).  The draft Pillar One agreement would also explicitly
require signatory jurisdictions to withdraw discriminatory digital services
taxes or similar measures.  The Pillar One documents released by the Inclusive
Framework relate to Amount A; work on Amount B is ongoing.

Certain key pieces of the Pillar One MLC have already been subject to OECD
public consultations and the comments received have been critical to informing
previous Inclusive Framework negotiations.  However, the recent release
represents the first time that a complete draft text of the Pillar One MLC
documents is available to the public.  The Treasury Department is especially
interested in comments related to novel issues identified by a review of the
complete text, implementation and administrability issues (including the balance
between simplification and technical precision), and technical adjustments to
address errors or clarify the operation of the Pillar One MLC provisions.  

Those interested in providing input should submit written comments by Monday,
December 11, 2023.  All comments must be submitted electronically to the
following email address: OTP_Pillar1MLC@treasury.gov.

Please note that all comments received will be made public.

###

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November 25, 2024
U.S. Department of the Treasury Releases New Report Showing State Small Business
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the Community Development Financial Institution Fund


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