On 26 September 2024, the OECD Inclusive Framework published a Model Competent Authority Agreement to assist jurisdictions that have implemented the simplified and streamlined approach under Amount B to provide tax certainty. The MCAA is mainly intended to be applied in relation to Covered Jurisdictions as defined in the 17 June 2024 guidance. However, the OECD notes that Inclusive Framework members may use the MCAA as a model for negotiations with jurisdictions that are not defined as Covered Jurisdictions. This workstream has remained pending since the release of the guidance reports in February and June 2024. Therefore, the MCAA brings Amount B one step further toward completion and political agreement, in light of the envisaged local implementation commencing in fiscal years beginning after 1 January 2025.
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