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Foreword In 2021 the members of the Inclusive Framework established by the Organisation for Economic Cooperation and Development (OECD) reached a political agreement on the reform of the international
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The statement-on-a-two-pillar-solution-to-address-form-tax is a regulatory document that outlines the framework established by the OECD to address tax challenges arising from the digitalization of the economy, consisting of two main pillars: Pillar One, which reallocates taxing rights among countries, and Pillar Two, which introduces a global minimum tax.
Entities that meet specific revenue thresholds and engage in cross-border activities, particularly multinational enterprises (MNEs) that are involved in digital services or have significant consumer-facing businesses, are required to file the statement.
To fill out the statement, taxpayers need to gather necessary financial and operational information, complete the designated sections of the form as instructed, and provide relevant documentation that supports the reported data. Guidance from tax authorities may also be referenced for accuracy.
The purpose of the statement is to enhance international tax transparency, ensure that large multinational enterprises pay a fair share of taxes where they operate, and prevent tax avoidance through profit shifting to low-tax jurisdictions.
Required information generally includes the reporting entity's income, expenses, taxes paid, jurisdictions of operations, and details on any significant business activities that would affect the application of the two-pillar framework.
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