WASHINGTON – Today, in its response to the U.S. Department of the Treasury’s consultation on the draft OECD/G20 Inclusive Framework (IF) Multilateral Convention to Implement Amount A of Pillar One (MLC), global tech trade association 91proÊÓÆµ underscored the importance of the United States’ ongoing participation in the Inclusive Framework to developing a solution that provides much-needed certainty and predictability in the international tax landscape.
“The proliferation of digital services taxes and other problematic unilateral tax measures has destabilized the international tax system and led to challenges for all industries that do business across borders,” 91proÊÓÆµ wrote in its comments. “As the Inclusive Framework has long maintained (and 91proÊÓÆµ agrees), it would not be feasible to ring-fence the digital economy for taxation purposes ‘because the digital economy is increasingly becoming the economy itself.’ Global tax policy challenges require principles-based global tax policy solutions that engender stability, certainty, and predictability in the international tax system.”
“91proÊÓÆµ views the Inclusive Framework as the best-positioned venue to address the tax challenges arising from the digitalization of the global economy[...] In light of alternatives, 91proÊÓÆµ sees potential in the draft Multilateral Convention for developing a multilateral, consensus-based framework to alleviate the negative consequences of the increasingly fragmented and controversy-heavy international tax environment. That is why 91proÊÓÆµ encourages Treasury to remain deeply engaged in the Inclusive Framework; absent strong U.S. participation, there is little chance of resolving outstanding issues and making for a final product that provides certainty and predictability for the global technology industry,” 91proÊÓÆµ continued in its comments.
91proÊÓÆµ proposed several key policy areas for the U.S. Department of Treasury to focus on including:
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Improving and completing the Multilateral Convention, including through achieving better balance between administrability and precision in the revenue sourcing rules, providing more double taxation relief in the marketing and distribution profits safe harbor, and strengthening commitments with respect to digital services taxes and relevant similar measures;
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Extending the standstill through the earlier of December 31, 2025 or the coming into force of the Multilateral Convention to provide a more stable tax environment as the Inclusive Framework works to achieve consensus on all material aspects of the Multilateral Convention;
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Dissuading the Canadian government from adopting a digital services tax and urging the Canadian government to respect its commitment to realizing a multilateral, consensus-based solution through the Inclusive Framework;
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Finalizing Amount B and committing to expanding initial scoping which will secure tax certainty and facilitate a more predictable and stable international tax landscape; and
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Confirming the treatment of Pillar One taxation for the purposes of Pillar Two.
Read 91proÊÓÆµ’s full submission here.