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Writer's pictureKuldeep Sharma

Should Developing Countries Go Ahead with Amount A MLC?

Many thanks to Taxsutra for publishing my article.


Amount A is a complex set of rules and may not yield enough revenues for the developing countries. Most importantly, adoption of Amount A MLC will take away application of DSTs/EL, which are already yielding handsome revenues for countries that have implemented them and that too, at a very low administrative cost.


In response to General Assembly resolution 77/244 on the “Promotion of inclusive and effective international tax cooperation at the United Nations”, the UN Secretary-General has presented the final version of the report in late August 2023 and has identified three viable options, in response to which, the African Union has opined that UN Tax Convention will ensure a level playing field that is central to a coherent international tax system. Developing countries need to focus more on the happenings at the UN and strive for equitable solutions at the UN rather than at the OECD. Hence, developing countries will be well-served if they let pass the Amount A MLC.




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