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To print this article, all you need is to be registered or login on Mondaq.com. 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 ....