19
Accepted
Pillar One will operate within a multilateral administrative framework, with the emphasis on international cooperation.
Conclusion
Pillar One will operate within a multilateral administrative framework, with the emphasis on international cooperation. This will be very different to how HMRC currently ensures compliance with its tax regime.58 Getting 140 tax jurisdictions to agree on a framework for administering the new system will be a key challenge, but it may be even more of a challenge for some jurisdictions to then operate the system as intended. HMRC and HM Treasury acknowledged that work will be needed to increase the capacity of some 50 Q 37 51 C&AG’s Report, figure 13 52 Qq 49–51 53 Qq 34, 56 54 Qq 65–68, 70–75 55 Q 69 56 Qq 38, 39 57 Qq 82, 84 58 Q 56 14 The Digital Services Tax jurisdictions, while pointing out that the cooperation of some jurisdictions (such as those where Pillar One payers are headquartered or those that will be required to reallocate tax receipts under Pillar One) will be more important than others.59
Government Response Summary
The government agrees with the observation and commits to providing the committee with the UK's objectives for the multilateral administrative framework, including audit arrangements, by June 2023.
Government Response
Accepted
Government Response
Accepted
HM Government
Accepted
The government agrees with the Committee’s recommendation. Target implementation date: June 2023 Unlike Pillar One, which is underpinned by a multilateral convention, Pillar Two must be implemented unilaterally in line with OECD Model Rules but with some multilateral aspects such as a standard template information return which can be exchanged between jurisdictions. The government has introduced legislation in Finance (No. 2) Bill 2022-23 to implement Pillar Two rules. The wider objectives for the development of the multilateral administrative framework for Amount A of Pillar One are set out in OECD publication of 6 October 2022.We will write to the committee with UK’s objectives for the multilateral administrative frame working, including audit arrangements.
Source
Committee
Public Accounts Committee
Inquiry
Digital Services Tax
Report
Forty-Fourth Report - The Digital Services Tax
05 Apr 2023
HC 732
Addressee Bodies
HM Treasury
Timeline
Recommendation age
3.3 yrs
Report published
05 Apr 2023