In the backdrop of the recent releases of Public Consultation Documents by the OECD on Amount B under Pillar One and Tax Certainty for the GloBE Rules under Pillar Two, it is expected that a common standard would be defined by the OECD for an APA-like mechanism to be adopted in the context of the GloBE Rules. Further, OECD has opined that taxpayers can make use of the mechanisms available to avoid future disputes in relation to the application of Amount B through APAs.
With above stated developments on the anvil arising out of the Two-Pillar Solution having direct impact on APAs, it is clearly visible that the APA regime has immense opportunity for growth.
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