Companies Seek Clarity on OECD Draft Rules’ Data Requirements

The global tax deal’s profit reallocation rules offer flexibility for companies that can’t access the data that’s called for—but they need more clarity to avoid disputes among countries, practitioners said.

Under last year’s agreement to overhaul the global tax system, the world’s largest multinationals will see their profits reallocated from where they’re currently taxed to the market jurisdictions where those products and services are consumed by the final or end customer—known as Amount A. Draft rules, released Friday for public input, outline how companies should identify that end consumer’s jurisdiction, transaction-by-transaction.

If a company can’t get the required information on ...