The Organisation for Economic Cooperation (OECD) has proposed overhauling rules ...
However, most business-to-business companies, like a car parts maker for example, would not be covered. Nor would companies in extractive or commodities industries.Provided a company falls in the scope, it would have to be determined whether it has a big enough operating presence in a country to be taxable, called a ‘nexus’ in international tax.
The formula would apply to the portion of a company’s global group profit reported to financial regulators that is deemed to be above what routine operations earn. Countries that consider that they were better off under existing rules would have to be prepared to make their case for exceptional treatment before a binding dispute resolution mechanism.The OECD proposals also aim to simplify existing rules for pricing internal transfers from one part of a company to another, which are currently the source of more than half of international tax disputes.
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