The OECD has launched a consultation on input on Extractives Exclusion under Amount A of Pillar One. They are also holding a public consultation meeting on the matters that need to be addressed as part of the Implementation Framework to support tax authorities in the implementation and administration of the Global Anti-Base Erosion Model (GloBE) Rules under Pillar Two.
Public Consultation on Extractives Exclusion under Amount A Pillar One
The OECD has launched a consultation on the Extractives Exclusion under Amount A of Pillar One. The Extractives Exclusion will exclude from the scope of Amount A the profits from Extractive Activities. The exclusion applies where a group derives revenue from the exploitation of Extractive Products and the group has carried out the relevant exploration, development, or extraction.
This approach reflects the policy goal of excluding the economic rents generated from location-specific extractive resources that should only be taxed in the source jurisdiction, while not undermining the comprehensive scope by limiting the exclusion in respect of profits generated from activities taking place beyond the source jurisdiction, or later in the production and manufacturing chain.
However, the public consultation document does not reflect consensus among members of the OECD/G20 Inclusive Framework on BEPS regarding the substance of the document. The deadline for submitting written comments to the OECD on the Extractives Exclusion is Friday, 29 April 2022.
Implementation Framework of the Global Minimum Tax
The OECD has published the comments it received from stakeholders on the Pillar Two Global Anti-Base Erosion Model (GloBE) Implementation Framework, in advance of the public consultation meeting which will take place on Monday, 25 April 2022.
The OECD will discuss the input provided in response to the consultation at the public meeting and consider the mechanisms to put in place in order to ensure that tax administrations and multinational enterprises can implement and apply the GloBE Rules in a consistent and co-ordinated manner.
Stakeholders can register by 5pm (GMT) on Friday, 22 April 2022 to attend the public consultation meeting on 25 April.
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