Public Input on Draft OECD/G20 Inclusive Framework Pillar One Multilateral Convention Text

On December 19, 2023, the U.S. Department of the Treasury published the comments received pursuant to Treasury’s request for public input on the draft OECD/G20 Inclusive Framework Multilateral Convention to Implement Amount A of Pillar One (Pillar One MLC) and accompanying documents.

The request for public input was announced on October 11, 2023, following the Inclusive Framework’s Task Force on the Digital Economy’s release of the current draft text of the Pillar One MLC, the Explanatory Statement to the Pillar One MLC, and the Understanding on the Application of Amount A Certainty. The input request, which was open to all members of the public, closed on December 11, 2023.

The three documents released on October 11 represent a years-long effort to find broad consensus among over 140 Inclusive Framework countries on a reallocation of taxing rights that better reflects the modern global economy. The release of the documents was the first time that a complete draft text of the Pillar One MLC documents had been made available to the public. Treasury is now reviewing the comments as negotiations to finalize the Pillar One MLC documents continue among OECD/G20 Inclusive Framework members.

All comments are available for public review below.

Public Comment from the Information Technology Industry Council

Public Comment from the U.S. Chamber of Commerce

Public Comment from the American Chemistry Council

Public Comment from Association of International Certified Professional Accountants

Public Comment from Amazon

Public Comment from Novo Nordisk Inc.

Public Comment from Anand Desai

Public Comment from the American Petroleum Institute

Public Comment from the Digital Economy Group

Public Comment from Engine

Public Comment from Ernst & Young LLP