Proposal for a Global Taxation System
– DAGTVA truth table –
DAGTVA® – Distribution of MNE profits
DAGTVA® – Distribution of MNE profits
| No. | Problems exposed, requests, constraints and subjects | Origin | Pg | Li | Doc |
| 102 | Ap – Mt C – benefit for amount A which gives entitlement to amount C. | Pillar 1 | 16 | 25 | RBMct |
Quote : Appendix – Detailed proposal on profit allocation
Amount C – Generalities (RBAcg)
65. In relation to Amount C, it would also be important to ensure that the profit under Amount A could not (whether in whole or part) be duplicated in the market jurisdiction (RBMcb), for example based on an argument that some or all of the profit under Amount A is also in some way referable to the functional activity in the market jurisdiction which is rewarded by Amount C (RBMct). Further work on certain aspects of the detailed interaction of Amounts A and C would therefore be warranted.
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