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Overview. As discussed in prior blog posts,
Amount A is a proposed new taxing right over a share of residual
profit of MNE groups that fall within its defined scope. The
calculation and allocation of Amount A will be determined through a
formula that is not based on the Arm's Length Principle (ALP).
The formula will apply to the tax base of a group (or segment where
relevant) and will involve three components: Step 1: a
profitability threshold to isolate the residual profit potentially
subject to reallocation; Step 2: a reallocation percentage to