Association OECD Comment Letter

The Association of the International Certified Professional Accounts ("Association") appreciates the opportunity to provide comments on the transitional Country-by-Country Reporting (CbCR) safe harbour and the "once out, always out" rule. The Association recommends that the Organisation for Economic Co-operation and Development (OECD) clarify that a Multinational Enterprise Group ("MNE Group") is only required to meet a Transitional CbCR Safe Harbour for a jurisdiction once that jurisdiction is subject to one of the Pillar 2 charging mechanisms (i.e., qualified domestic minimum top-up tax (QDMTT), income inclusion rule (IIR) or undertaxed profit rule (UTPR)), under the "once out, always out" approach. This will ensure that they do not face unintended compliance burdens or exclusion from transitional relief in subsequent years.