Die OECD Model Rules für eine Neuverteilung von Besteuerungsrechten

On February 4^th and 14^th, as well as on April 4^th, 2022, the OECD Inclusive Framework published the OECD Model Rules for Nexus and Revenue Sourcing, for Tax Base Determinations, and for Domestic Legislation on Scope (Pillar I/Amount A). The templates for domestic legislators contain an extremely complex and comprehensive set of rules including necessary legal definitions to finally implement the global tax deal. If the OECD has its way, national legislators should transpose the rules into domestic laws as early as 2022 and they should already become effective in 2023. In this article, Stefanie Stöcklinger provides an overview on the framework for a new system of profit allocation for large multinational entities among so-called market jurisdictions.