On 12 July,2023 an update was issued in relation to the status of the BEPS 2.0 project which provides some important, albeit brief, updates in relation to Pillar One as well as the Subject to Tax Rule (STTR) from Pillar Two.
- Pillar One – Amount A-Text has been developed for the multilateral convention (“MLC”) on Pillar One’s Amount A. According to the Outcome Statement, the MLC will be opened for signature in the second half of 2023 and a signing ceremony will be arranged by year-end. The objective is for the MLC to enter into force in 2025. Additionally, the Outcome Statement announced that IF members have agreed to refrain from introducing new DSTs or similar measures during the period between 1 January 2024 and 31 December 2024.
- Pillar One – Amount B– Consensus has been reached on many aspects of Amount B. A public consultation has been launched on 17 July 2023 on various topics with comments due to be submitted by 01 September 2023. Following this, a final report on Amount B will be published which will then be incorporated in the OECD TP Guidelines by January 2024. The report shall include critical items such as consideration for low-capacity jurisdictions as well as timelines for transitioning to Amount B for all jurisdictions.
- Pillar Two – STTR-The OECD have completed work on both an STTR model provision and commentary as well as an MLI and Explanatory Statement to facilitate implementation.