The OECD-led global tax overhaul must address the needs of developing countries, particularly through measures that would simplify some transfer pricing and create a treaty-based minimum tax rule, India’s finance minister said.
Last year’s global tax agreement includes a commitment to create a measure known as “Amount B,” which aims to reduce transfer pricing disputes by streamlining rules for certain activities—a measure that could be welcomed by tax authorities with fewer resources to conduct complex analyses of multinationals’ intragroup transactions. The agreement also includes a “subject to tax rule,” or STTR, that would help developing countries capture more revenue in ...