As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on the Extractives Exclusion under Amount A of Pillar One.

The Extractives Exclusion will exclude from the scope of Amount A the profits from Extractive Activities. The exclusion applies where a Group derives revenue from the exploitation of Extractive Products and the Group has carried out the relevant Exploration, Development or Extraction. This approach reflects the policy goal of excluding the economic rents generated from location-specific extractive resources that should only be taxed in the source jurisdiction, while not undermining the comprehensive scope by limiting the exclusion in respect of profits generated from activities taking place beyond the source jurisdiction, or later in the production and manufacturing chain.

A public consultation document (également disponible en français) has been released in order to obtain public comments. The stakeholder input received on the Extractives Exclusion will assist members of the Inclusive Framework on BEPS in further refining and finalising the relevant rules.

Interested parties are invited to send their written comments no later than 29 April 2022. Instructions for submitting comments can be found in the consultation document.


(Source: OECD Tax)

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