Pillar I electrónico the marketing and distribution safe harbour (MDSH) as applicable to licensed manufacturers and centralized business models : does it fulfil its policy objective? Vikram Chand, Camille Vilaseca
By: Chand, Vikram
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Contributor(s): Vilaseca, Camille.
Material type: 
ArticleSubject(s): PRIMER PILAR (OCDE) | AMOUNT A (PRIMER PILAR, OCDE) | PRINCIPIO DE PLENA COMPETENCIA | PRECIOS DE TRANSFERENCIA
In:
Intertax v. 51 n. 8/9, August/September 2024, p. 572-594Summary: The new Pillar I Amount A system aims to reallocate a portion of in-scope MNEs’ residual profits to market countries. This said, there could be many instances when an MNE already reports residual profits in the market country under the current system, for example, when it operates with a substantial physical presence (which is entrepreneurial in nature) in the market country. In order to avoid the double taxation/double counting of what is known as ‘residual profits’, a Marketing and Distribution Safe Harbour (MDSH) mechanism was first developed in the 2020 Blueprint and redesigned in the 2022 Progress Report. This article addresses the question as to whether the MDSH as designed in the Progress Report meets its objective, particularly after briefly describing it as drafted in both reports.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | OP 2141/2023/8/9-5 (Browse shelf) | Available | OP 2141/2023/8/9-5 |
Resumen.
The new Pillar I Amount A system aims to reallocate a portion of in-scope MNEs’ residual profits to market countries. This said, there could be many instances when an MNE already reports residual profits in the market country under the current system, for example, when it operates with a substantial physical presence (which is entrepreneurial in nature) in the market country. In order to avoid the double taxation/double counting of what is known as ‘residual profits’, a Marketing and Distribution Safe Harbour (MDSH) mechanism was first developed in the 2020 Blueprint and redesigned in the 2022 Progress Report. This article addresses the question as to whether the MDSH as designed in the Progress Report meets its objective, particularly after briefly describing it as drafted in both reports.
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