The Interplay Between the OECD's Pillar One and Pillar Two: Transition From Technical Analysis to Practical Application.

Last week, we discussed the technical interdependencies existing between the OECD's Pillar One, its Pillar two, and ultimately U.S. International tax. In this week's discussion, it's simple. We seek to demonstrate the application of the interplay between the Pillar One and Two rules, and the U.S. International tax regimes. To do so, we will use details gathered from the tax affairs of a multinational enterprise group (referred herein after as "an MNE").

MNE A is a manufacturer of fitness equipment that has respectively had revenues and profit-before-tax results for the current year of $19.2B and $2.4B. It historically holds three main divisions: B-2-C consumer products ("B2C"), B-2-B fitness equipment products ("B2B"), and B-2-B warranty & repair services ("warranty"). Using approximations, 50% of its operational results are derived from North America (U.S., Canada, & Mexico); 20% is derived from the European Union; and, 30% is derived from the Asian, Australian, Middle Eastern, African, and Latin American regions. This year, in alignment with new global workforce trends where workers are increasingly working from home, thus driving global gym membership increases, with CFC 3 registering an IP impairment $1.25B loss (related to the loss in relevance of its IP assets as it relates to B-2-C product sales. i.e. home gym products and equipment.), MNE A has decided to strengthen the quality of its B-2-B and B-2-C apparels by acquiring a third-party manufacturer - Robust Iron, Inc ("Robust"). The purchase price was $1.5bn (with inherited / acquired basis of $.9B). Since inception until recent acquisition, Robust has always derived all of its income from services similar to the ones it was rendering immediately before the acquisition transaction. And, the income-producing activities of MNE A's B-2-B division align seamlessly with those of Robust. As such, pre and post-acquisition, there were no business processes' arrangement or realignment thereby changing the activities of the target. Robust respectively has net operating losses carried forward for the years '08 thru '10 (these periods are elimination eligible prior periods within the meaning of Annex B Section 4 Para 13(d)(i)&(ii)), and current year loss of .1B, .3B, .2B, and .1B. Post acquisition, financial accounting management has decided these are not to be considered as prior period adjustment. Management also does not plan on, and as such has certified that for the next five years, either divesting itself from Robust's assets, dissociating itself from its transferred employees, or discontinuing the services and products that it provides. In year '21, Robust had also acquired Sharper Iron, Inc. ("Sharper"), where Sharper also has an accumulated and unused NOL of .2B. This, in the hands of Robust, immediately before Robust's acquisition. And, similarly to Robust, since inception until Robust's acquisition, Sharper has carried on the same income-producing activity. Which, post-acquisition, was continued by Robust. And, now by MNE A.

MNE A is in a jurisdiction that is not a party to Pillar One's Amount A's regulations. Within MNE A, there are four main controlled foreign corporations that hold directly and / or indirectly all of the entities within the group's legal structure. These are:

• CFC 1 - which holds 23 entities under its full control only (100% indirectly and directly owned). Non-Cons F/S asset value of $10 Bn. Resident to a party jurisdiction. CFC 1's specified equity interests ("SEIs") are 81% indirectly held by UPE through a single tier level.
• CFC2 - which owns 20 entities under its full and majority (greater than 50% ownership) control; 14 of which are 100%-indirectly owned by the UPE. Resident of a non-party jurisdiction. Non-Cons F/S asset value of $7 Bn. CFC 2 is indirectly held by UPE through a two-tier levelling.
• CFC 3 - Which holds 30 entities under its full control; 17 of which are indirectly-owned by both CFC 1 and the UPE; and, 13 by CFC 2: 9 of which are held by UPE. Totaling to 87% of its SEIs owned by the UPE. Resident to a party jurisdiction. Non-Cons F/S asset value of $8.5 Bn. This is my DPE.
• CFC 4 - Which holds 17 entities under its majority control. 6 of which are indirectly held by CFC 1 and the UPE, and 11 of which are directly owned. Resident to a party jurisdiction. Non-Cons F/S asset value of $3.6 Bn.

During the current year, MNE A has also undergone the following transactions:

• Internal Asset Reorg: $.75B Cross-Border IP transfer. Asset creation cost in the hands of seller: $.3B. Gain recognized by selling MNE member (CFC 4) is $.45B. 15% of accounting gain was actually taxed at 21%. Here, this will be subject to the qualifying reorganization adjustment. tax gain will be allowed to remain in financial accounting profit calculation. Page 109 of the MLC, Annex B Section 4 Para (8)(a) & (b). Useful life used for amortization is 15 years. Also, the transaction meets the definition of a qualifying reorganization within the meaning of Annex B Section 4 Para (13)(f).
• Additionally, MNE A's HQ agreed under pressure from the directors of its subsidiaries, related to the increasingly unfavorable geopolitical environment of country Y, to provide instructions to its CFC 2's management team to pay certain governments agents an amount of $15M in order to favorably protect its business operations from local issues potentially harmful to its operations if unaddressed. In UPE jurisdiction, such practices are deemed illegal. MNE A also allowed for lobbying dues to be paid in France & the UK in amount of $20M. Such practices in UPE jurisdiction are allowed. In the current year, MNE A and its 4 main CFCs had the following:
• Respective Financial accounting profit or (loss): $10.1B, $4B, $1.1B, $2B, and 1.9B. Combining for the $19.1B.
• The remainder of revenues of $0.1B was earned by a small division of MNE A, is located in a jurisdiction nearby to MNE A's; the revenues of which are 100% sourced within that jurisdiction. This standalone division meets the definition of being an "autonomous domestic business". (Used as part of revenue testing only... Required to be carved out for profit-before-tax calculation purposes.) See Annex C. Section 5, Para 2(a)(i),(ii),(iii); Para 3; & Para 4.
• Value added Tax: $.22B, $.12B, $.04B, $.07B, and $.069B.
• Intra-MNE Div (100% ownership): $.980B from CFC 1 to UPE.
• CFC 1 pays a gross management fee to the UPE of $.131578B, and a net of $.125B. CFC 1 is subject to reduced withholding tax of $6.5789M. The reduced covered tax treaty rate on the fee income is 5%. The corporate tax rate in UPE's jurisdiction is 21%. And, the average state income tax on profits of body corporates in jurisdiction of MNE A is 4%. The management fee received will be cancelled in the hands of the recipient by way of the grossing up of the withholding tax paid and adjusting the elimination profit calculation downward: called the "current withholding tax downward adjustment". ($6.5789M/.21).
• Withholding tax on intra-MNE cross-border payment above: $.049B. These are not considered covered taxes within the meaning of Annex B, Section 4 Para 13(c)(iv).
• The current consolidated income tax expense is $.5B.
• Gain from SEI Disposition: CFC 1 gain $. 33B
• Impairment losses of MNE A (notwithstanding the CFCs respective impairment losses below): $.46B
• Abstract Payments: CFC 2 - $15M Eur / CFC 4 - $20M
• Step-up in value of intra-MNE reorganized IP transferred: $750M. useful life: 15 years.
• Step-up in value of assets acquired from Robust's acquisition: $600M. useful life: 15 years.
• Realized Impairment loss adj: $700M to all 4 main cfcs: equal share.
• Disclosed FIN 48 WW tax liability: $1B (global) / Region 1: $.25B / Region 2: $.4B / Region 3: $.2B / Region 4: $1.5B.
• Interest on tax liabilities: cfc 1 - $14M / cfc 3: $7M. (compliant).
• .68B out of the .98B of dividend distribution meets the FPHC gain income definition of MNE A's jurisdiction. And, is thus taxable to MNE A's during the current year at a rate of 21%. the gain is recognized in the tax return of MNE A. And, shown to be related to a distribution over basis and over previously taxed earnings and profits of CFC 1, CFC 3, and CFC 4.
• Given that MNE A is proactive in its determination of its yearly tax liabilities on both operational results and on transactions, 95% of the .68B was determined by external advisors to be the amount to be taxed. As such, .645B out of the .68B has been included in the global consolidated financial statements of MNE A. With the associated taxes determined at a rate of 21%.
• Realized impairment losses related to warranty's assets of $.2B.
• Financial accounting Stock based compensation expense for the MNE was $225M. Pg. 101 of the MLC. Annex B, Section 4, para 2(b)(iii).
• Tax accounting stock-based compensation expense for the MNE was $236M. Pg. 101 of the MLC. Annex B, Section 4, para 2(b)(iii).
• Four years ago, $98M in stock options were issued and deducted by the MNE for financial accounting purposes. $30M of those were exercised. $34 M expired this year. And, the remaining $34 is still unexercised. expired. Pg. 101 of the MLC. Annex B, Section 4, para 2(b)(iv).
• This year's net pension liability expense is $119M. MNE A has a pension plan provided through a pension fund. Pg. 101 of the MLC. Annex B, Section 4, para 2(b)(v).
• This year's net pension contribution expense is $91M. Pg. 101 of the MLC. Annex B, Section 4, para 2(b)(v).
• CFC 1 owns a foreign branch - FB 1 - that operates in and as such is taxable in a jurisdiction other than the jurisdiction of residence of CFC 1 (jur Y). Its latest jurisdiction Y's tax return shows that it has profits of $75M (no "Annex B Section 4, Para 2" adjustments needed here. See reference below).
• FB 1's Jurisdiction Y's original tax return is filed 180 days before the filing of the Amount A tax return of MNE A. Pg 288 of the explanatory statement Para 1251, 1247 & 1248, & 1249. Annex B Section 3 Para (3).
• MNE A is subject to an audit in the current year '24. The audit relates to the activities of FB 1 for the years '19 thru '23. In fact, per MNE A's tax laws, the activities of FB 1 give rise to branch subpart f income under IRC section 954(d)(2). Here, the effective tax rate on the recidivated branch-related income in FB 1's jurisdiction is 14%. Thus, though considered a manufacturing branch, it failed meet the two-prong (less than 90% and less than 5 points than the statutory CIT) test required to be met to get the manufacturing branch exception. See. Regs. Sec. 1.954- 3(b)(1)(ii)(b).
• This adjustment also caused an IRC 905(c) redetermination with respect to the income taxes paid by the foreign branch during the year 2022 that would be subject to a lesser foreign tax credit limitation.
• To be exact, the adjusted manufacturing branch subpart f taxable income base was $150M. the incremental federal income tax liability on said base is $31.5M. MNE A made a $25.2M payment to satisfy the audit assessment. The incremental and favorable 905(c) credit redetermination available to offset the new tax liability was $3.8M. There is $2.5M in payment remaining to address this audit assessment.
• The $150M of audit assessment, though related to period '19 thru '23, meets the definition of a "taxable profit spreading adjustment". Therefore, the period over which the taxable profit spreading adjustment will be made is 5 periods. See Annex B Section 4, Para 4(c)(ii)(A)(2). Page 291, para 1256 and 1261 of the explanatory statement to the MLC.
• FB 1's location is within a jurisdiction other than CFC 1's residence jurisdiction. Annex Section 4 Para 5(b).
• Its consolidated global depreciation and payroll expenses are respectively as follows: Depreciation of $.8B, and payroll of $1B.
• When it comes to jurisdictional depreciation and payroll, the numbers were as follows:
• Depreciation:

MNE A = $.51B | CFC 1 = $.12B | CFC 2 = $.14B | CFC 3 = $.17B | CFC 4 = $.16B.

• Payroll:

MNE A = $.53B| CFC 1 = $.15B | CFC 2 = $.14B | CFC 3 = $.17B | CFC 4 = $.16B.

• Each entity, including MNE A, respectively has $1.3B, $0.4B, $0.2B, $0.3B, and $0.2B of operational profits. Combining for the $2.4B of global operating profits noted earlier above. (Note: we ignore the profits from our taxable presence entity - FB 1 - as they are minimal. it is idem for its payroll and depreciation amounts. We deem those amounts to be attributable to its parent CFC1. this for purposes of exercise simplification and immateriality).

Now that all the details tied to MNE A's activities during this year are provided above. We now look to align MNE A's results with Pillar One's Amount A's Multilateral Convention rules.

To do so, we will first address the determination of MNE A's Pillar One's Amount's "adjusted revenues" and consolidated "adjusted profit-before-tax" amounts.

Step 1: Adjusted Revenues

Here, the adjusted revenues' test is done at the consolidated level. The appropriate guidance here is from the MLC's Part II, Article 2, Para (c). We apply as follows:

1. Consolidated Revenues = $19.2B
2. Less: Value Added Tax = - $.22B. MLC's Part II, Article 2, Para (c)
3. Less: SEI Div to UPE = -$.98B. MLC's Annex B, Sec 2(1)(a)(ii)
4. Less: UPE Mgmt Distr = -$.131578B. MLC's Annex B, Sec 2(1)(a)(ii)
5. Less: SEI Disp Gain Alloc = -($.33B*.8). Here, the gain is spread over 5 years. Annex B, Section 2(1)(b)(iii).
6. Add: CFC 7's Impairment Loss = $.46B.
7. Add: CFCs 1-4 Impairment Loss =$.7B.
8. Add: CFC 3 Impairment Loss = $1.25B. All unrealized losses are disallowed; only realized ones (Warranty div - $.2B) are allowed. See MLC's Annex B, Sec 2(1)(a)(iii)(B) | Explanatory Statement to the MLC, para 1099, pg. 247. |

Pillar One's Amount A's Adjusted Revenues = $20.014422B

We assume here that 1$ equals 1 Euro.

Step 2: Adjusted Profit Before Tax

Here, the adjusted profit-before-tax test is done at the consolidated level. The appropriate guidance here is from the MLC's Annex B, Sec. 4, Para 2(c). We apply as follows:

1. Consolidated Profit-Before-Tax: $2.4B
2. Add: C/Y Stepped-Up Basis Depr Disallowed = ($.6B/15) = $.04B. See Annex B, Section 4, Para 2(b)(i)(A). Annex B Section 4 Para (8)(b). On another note, per the details provided, pre and post-acquisition business continuities were met. See Pg. 261 of the explanatory statement to the MLC, Para 1137. Annex B, Section 2 Para 3(b)(i)&(ii), which aligns closely with U.S. Reg.§ 1.368-1(d) (1), (2), & (3).
3. Add: CFC 3's Impairment Loss = $1.25B. The impairment is unrealized since that affected asset, or section, or division of CFC 3 has neither been disposed of, nor has the cfc been liquidated.| Annex B, Section 4, para 2(b)(vi)(B) & Annex B, Section 4, para 2(a)(iii). |
4. Less: Robust C/Y Loss = -$.1B. Annex B, Section 4, Para 6(a)
5. No adj: Robust '08-'10 NOLs = $.0B. Given how ancient the NOLs are, we assume and as such treat them as "non-eligible elimination losses". They do not meet Annex B, Section 4, Para 6(b)(i).
6. Less: Sharper's acquisition NOLs = -$.2B. Annex B, Section 4, Para 6(b)(ii)
7. Less: CFC 4 Accounting Gain = -$.45B. Annex B Section 4 Para (8)(a) & (b)
8. Add: CFC 4 tax gain = (.$45B * .15). Annex B Section 4 Para (8)(a) & (b)Taxpayer will adjust its basis in the assets concerned in adherence with the "tax fair value adjustment" provisions. See Annex B section 4, Para 10(a) thru (c).
9. Add: Illegal payment #1 = $15M. Other $20M is legal and deductible per MNE A's laws.
10. Add: C/Y Tax Expense = $.5B. Annex B, Section 4 , para 2(a)(i).
11. Add: Def Tax Expense = $1B. Annex B, Section 4 , para 2(a)(ii).
12. Add: Book Stock-Comp Exp=$.225B. Annex B, Section 4 , para 2(b)(iii).
13. Less: Tax Stock Exp = -$.236B. Annex B, Section 4 , para 2(b)(iii).
14. Add: P/Y Stock-based Exp = $34M. Annex B, Section 4, para 2(b)(iv).
15. Add: Net Pen Liab Exp = $119M. Annex B, Section 4 , para 2(b)(v)
16. Less: Net Pen Contr Exp = $91M. Annex B, Section 4 , para 2(b)(v)
17. No adj: For CFC 1 Div paid = $0. For purposes of the exercise, we'll assume that the dividend were eliminated for this section of the calculation process.
18. No correlated withholding tax downward adjustment when it comes to the dividends paid from CFC to MNE A ("UPE"). Here, the nullification of the existence of the dividend within the "adjusted profit-before-tax" calculation turns the payment into a non-covered payment. Plus, the dividend payment does not impact the P&L. The adjustment only applies unto withholding tax payment related to covered payment. See Annex B Section 4, Para 12(b). Annex B, Section 4, Para 2(a)(ii). See MLC, Part II, Article 2(J).
19. Less: Withholding Tax Downward Adj = -($6.5789M/.05) | $-.131578B | The adjustment is related and applicable only to the UPE Jur. It is part of its adjusted elimination profit per article 5(2)(f)(ii). Additionally, as opposed to the dividend payment above which had withholding taxes paid in relation to it, this payment is a covered payment within the meaning of the MLC, Part II, Article 2(J).
20. Add: Withholding Tax Upward Adjustment= ($6.5789M/.05) | $.131578B |The adjustment is related and applicable only to the CFC 1 Jur. It is part of its adjusted elimination profit per article 5(2)(f)(ii). Additionally, as opposed to the dividend payment above which had withholding taxes paid in relation to it, this payment is a covered payment within the meaning of the MLC, Part II, Article 2(J).
21. Less: Gain spreading from SEI Disp'n (CFC 7: a SEI) = ($. 33B / .8) | -$.264B |
22. Less: MNE Reorg Stepped-Up Basis Depr Disallowed = $750M / 15 | -$50M | Annex B, Section 4, para 8(b). |
23. Less: 3rd Party Acq'n Stepped-Up Basis Depr Dis'd = ($600M / 15)=-$40M | | Annex B, Section 4, para 8(b). |
24. Add: all CFCs' Impairment = ($.7B + $.46B) = $1.16BHere, only unrealized impairment losses are added back. | Annex B, Section 4, para 2(b)(vi)(B) & Annex B, Section 4, para 2(a)(iii). |
25. Less: Capital gain FPHCI = -$. 645B. We note here that although this item of adjustment is of subpart-f nature as the "branch subpart-f income" item of adjustment # 26 below, and that the usual determination related to the income-producing activities of the CFCs usually drive us to treating these as "taxable profit spreading adjustments (see item #26 rationale below). Here, per our details, the unique capital gain character of this specific subpart-f income determination guides us to Annex B, Section 4, Para 2(a)(iii)(B). That is the fact that the distribution is in excess of basis and available PTEP (interplay between IRC 959; IRC 301(c); IRC 316(a)(1)&(2), & Notice 2019-1) of the CFCs creates IRC 961(b)(2) gain described above. Which is considered a disposition (deemed) of stocks of the CFC creating negative basis, which is then recover by the capital gain. Whereby the basis in the CFCs' stocks is nil; and yet, they are still wholly owned by MNE A. Therefore, meeting the definition of Specified Equity Interests. Now, though uncommon to have subpart-f income calculation being part of consolidated financial statement's profit calculation, our exercise details above provide for the fact that MNE A specifically hired external advisors, who determined an approximate taxable base of $.645B out of $.68B. And, its associated tax liability ($.645B * .21). They are incorporated in the consolidated F/S. And, as such, were adjusted for purposes of the exercise. We would be remiss not to importantly highlight the muteness of the MLC as it relates to the treatment of audit assessments in the UPE jurisdiction related to the activities of its foreign group entities ("wholly-owned CFCs"). That is: the texts only explicitly discuss audit assessments of taxable presences: "taxable profit spreading adjustment". In light of such muteness, we use our understanding of the policy intent of the OECD's Amount A's MLC to define and be comfortable with our position in such cases of ambiguity usually found in practice. We explain below. If, rather than an IRC 961(b)(2) audit assessment (by way of IRC 954(c)(1)(B)) where the character of the income is of capital gain nature; it were rather assessments of IRC 954(d)(1) nature - foreign base company sales income - or of IRC 954(e) nature - foreign base company sales income, where the assessment is based on the tax consequences of the operational activities of the CFCs within the UPE's jurisdiction, rather than the consequences of transactions between wholly-owned CFCs and their UPE (MNE A), then adjustments such as the taxable equity transaction adjustment and the profit allocation adjustment to name a few out of those listed in "Annex B, Section 4, Para 7 thru 12" would not fit these situations. The sole fitting adjustment for our situations above is the "taxable profit spreading adjustment", per Annex B Section 4, Para 3(c). We explain below. We understand the texts to consider branches or permanent establishments (defined in accordance with article 5 of both the U.S. Model Tax Treaty and the OECD Model Tax Convention on Income and on Capital), as taxable presences. That is because they are usually liable to tax under the income tax regime of a jurisdiction other than the group entity residence or location jurisdiction. Equally, because businesses have to quantify their operational results in new or old jurisdictions, and hence the inescapable need to keep an independent set of books and records (at least one for tax purposes), we prima facie deem branches and / or permanent establishments to meet the U.S. tax definition of a qualified business unit ("QBUs"), as defined under IRC 989(a). We stress the importance of the word "initially" in the previous phrase because within a branch and / or permanent establishment, there may be more than one QBU. Reg. Sec. 1.989(a)-1(b)(2)(ii). Further, we understand CFCs ("group entities") to be per se QBUs. Reg. Sec. 1.989(a)-1(b)(2)(i)(A). Therefore, we note that group entities can either represent one or more QBUs. In instances, as ours, where the activities of the entities are independently kept in an independent set of books and records and are all taxed all at once under a net income tax regime of a jurisdiction (CFC residence jurisdiction) different from the jurisdiction of the UPE (jurisdiction imposing the assessment), then the group entities can be treated as "taxable presence" entities. And, the UPE will be treated as the "group entity". The result of which will provide for a "taxable profit spreading adjustment". Which matches the policy intent of the OECD when drafting the Amount A's MLC texts. That is: 1) adjustments related to operational results are included but spread over a number of years. And, 2) adjustments related to gains and losses related to stock ownership dispositions or deemed dispositions (especially 100%) are excluded from calculations.
26. Add: FB 1's branch Sub-F income = | $.15B / 5 = $.03B | This is an instance of "taxable profit spreading adjustment". 92.06% of the final tax liability due after the tax authorities' examination has already been paid (combination of actual payments and tax credits). The periods of spreading is determined to be over five periods. Sub-f incomes and their associated liabilities are usually not part of consolidated financial statements. As such, we equally consider them not to be a part of. See Annex B Section 4, Para 3(c)(ii)(A)(2). Page 291, para 1256 thru 1261 (specifically 1256 and 1261) of the explanatory statement to the MLC. Annex Section 4 Para 5(b).

We clarify that for all of MNE A's acquisition(s) or disposition(s) discussed in this exercise, no tax election(s) similar to IRC 338(h)(10), IRC 338 (g), IRC 336(e) were made. Thus, explaining the absence of "Annex B, Section 4, Para 9(a) adjustments: taxable equity transaction adjustment".

Adjusted Profit Before Tax = $4.7645B.

Amount A's Allocable Adjusted PBT = (($4.7645B - (10%*$20.014422B))*.25)

Amount A's Allocable Adjusted PBT = $0.69076445B

Step 3: Revenue Categorization, Revenue Sourcing, & Nexus Determination

Business Model Overview:

For this step, we have determined that under the old revenue sourcing rules, the revenues of each CFC were almost 100% sourced to the jurisdictions they were incorporated and tax resident of. Under the "Amount A's new sourcing rules, these revenues would source to the actual location of the final customers purchasing the wellness equipment.

On another note, the MNE's revenue sourcing map is being significantly disturbed by the new revenue sourcing rules. This, because of the business structure it has adopted over the years. That is: that of having one main regional independent distributor company handle the logistics of the finished goods. Under its normal modeling, each regional independent distributor purchases the goods from the MNE A (or headquarters) and resold the goods (after substantial improvement) either directly to third party gyms in countries different from its respective countries of incorporation; or, to other related MNE-group entities.

FIN 48 Position Overview:

We also know that MNE A's global FIN 48 tax is driven by 1) the uncertainty that lies around its revenues sourcing position in each of the different regions of the world, thereby affecting its tax yearly liabilities (i.e. sourcing and timing of recognition of revenues involved in its many installment sales' contracts with fitness gyms' clients); and, it is also driven by its tax position on the availability of and allowance for usage of PTEP as it relates to dividend distributions the likes of the $.98B distribution noted during this current year. Let's note that MNE frequently uses dividend payment for capital redeployment strategies. (i.e. little to no tax on div distribution when tax position on PTEP is uncertain, or to say the least, not strong). And, 25% of the FIN 48 position, created during this year, was 80% related to uncertainties around appropriate revenue sourcing; while, the remaining 20% was related to basis calculation (PTEP) and usage uncertainties.

Old Revenue Sourcing:

The below represent the revenue sourcing under old rules:

| MNE A = $10.1B = Jur A, B, & C | CFC 1 = $4B = Jur 1 | CFC 2 = $2B = Jur 6 | CFC 3 = $1.1B = Jur 11 | CFC 4 = 1.9B = Jur 16 |

| FB 1 = $.1B. = Jur 21 |

To recall, MNE A engages in the following income-producing activities:

1. B-2-B Sale of Consumer (fitness equipment) goods.
2. B-2-C Sale of Consumer (fitness equipment) goods.
3. Warranty & Repair Services to both B-2-B and B-2-C clients.

Geographically speaking, pre-Amount A's sourcing rules, its sales were regionally compartmentalized as follows:

1. Approximately 50% of its operational results are derived from North America (U.S., Canada, & Mexico). 40% - U.S. | 10% - Rest.
2. 20% is derived from the European Union.
3. 30% is derived from the Asian, Australian, Middle Eastern, African, and Latin American regions.

In terms of regional sales' responsibilities, the following has historically applied to MNE A:

• MNE A: responsible for the U.S., Canada, & Mexico.
• CFC 1: responsible for the EU region.
• CFC 2: responsible for APAC region.
• CFC 3: responsible for MEA region.
• CFC 4: responsible for LATAM region.
• FB 1: responsible for Australian region 1 (owned by CFC 1).
• All CFCs are wholly owned by USSH 2, which in turn is wholly owned by USSH 1 (MNE A).

Additionally, historically, the following rules were used to source revenues from MNE A's income producing activities:

• B-2-C Sales: sourced to manufacturing jurisdiction. IRC 863(b). IRC 862(a)(6) as applicable; with title passing without the U.S. on U.S-to-foreign sales.
• B-2-B Sales: sourced to manufacturing jurisdiction. IRC 863(b). IRC 862(a)(6) as applicable; with title passing without the U.S. on U.S-to-foreign sales.
• Warranty & repair Services: location of services performed.

The following key pieces of details ought to be provided.

• Each CFC purchases from MNE A, improves (substantial transformation) the purchased goods, and sells them to market.
• Each CFC plays the role of being a regional sales and distribution company. That is: they cover sales in multiple jurisdictions within its assigned world region.
• Lastly, the tax code references provided above pertain to the United States'. All other jurisdictions concerned have and apply similar sourcing rules.

New Revenue Sourcing Rules' Application - Amount A's MLC Rules

As dictated under the MLC's Part II, Article 6, Para 1 (a) & (b), our finalized categories of incomes below have been determined solely based on the true ordinary or predominant character of the transactions from which they derive. That is: we have analyzed them for purposes of determining and confirming their substance. This, notwithstanding their different legal forms. In that respect, for any transaction, the determination of which we could not reach using the different revenue categories (including the "specific allocation key method" of Part II, Article 6, Para 3(iii)) provided in the MLC's Part II, Article 7, we have, in accordance with the MLC's guidance in Part II, Article 6, Para 1(c), opted to use a default allocation key.

Given that we were required per the MLC's Part II, Article 6, Para 2, to determine and adopt reliable method(s) for purposes of sources our revenues following the new rules, we have analyzed the substance of our income-producing transaction per entity in order to arrive at new sourcing results. The details of which are provided below. We have also concluded from our analysis that our revenues from warranty services can follow the same reliable method of revenue allocation as that of the B-2-B sales or the B-2-C sales because they represent 7% of total adjusted revenues. Thus, adhering to Part II, Article 6, Para 3(ii)(A) & (B). And, to the extent to which there exists ambiguities in our revenue sourcing determination process, MNE A will in a timely manner seek an Advanced Certainty Request (a process similar to that of the U.S. IRS' Advanced Pricing & Mutual Agreement Program).

Now that we have highlighted MNE A's old revenue sourcing rules and global structure, along with its process to abide with the MLC's Amount A's new rules, we lay out below the sourcing rules used to determine to be applicable to MNE A's business structure.

• B-2-B Sales: Sourced to final customer jurisdiction. MLC's Part II, article 7, Para 1(a).
• B-2-C Sales: Sourced to final customer jurisdiction. MLC's Part II, article 7, Para 1(a).
• Warranty & Repair Services: MLC's Part II, article 7, Para 1(d)(i)(A)&(B).

The new sourcing rules have affected the MNE as follows:

MNE A: $10.1B

• | 87.5% of 40% (35%) total adjusted revenues are U.S. market-based. - Jur A. |
• | 9% of total adjusted revenues are Canadian market-based. Jur B. |
• | 6% of total adjusted revenues are Mexican market-based. Jur C. |

CFC 1: $4B

• | 20% of the 20% of total adjusted revenues are Irish market-based. Jur 1. |
• | 20% of the 21% of total adjusted revenues are French market-based. Jur 2. |
• | 20% of the 21% of total adjusted revenues are British market-based. Jur 3. |
• | 20% of 21% of total adjusted revenues are German market-based. Jur 4. |
• | 20% of 21% of total adjusted revenues are Russian market-based. Jur 5. |

CFC 2: $2B

• | 50% of 10.5% of total adjusted revenues are Chinese market-based. Jur 6. |
• | 12.5% of 10% of total adjusted revenues are Japanese market-based. Jur 7. |
• | 12.5% of 10% of total adjusted revenues are S. Korean market-based. Jur 8. |
• | 12.5% of 10% of total adjusted revenues are Indian market-based. Jur 9. |
• | 12.5% of 10% of total adjusted revenues are Singaporean market-based. Jur 10. |

CFC 3: $1.1B

• | 40% of 5% of total adjusted revenues are South-African market-based. Jur 11. |
• | 15% of 5% of total adjusted revenues are Turkish market-based. Jur 12. |
• | 15% of 5% of total adjusted revenues are Egyptian market-based. Jur 13. |
• | 10% of 5% of total adjusted revenues are Israeli market-based. Jur 14. |
• | 20% of 5% of total adjusted revenues are Saudi Arabian market-based. Jur 15. |

CFC 4: $1.9B

• | 40% of 10% of total adjusted revenues are Brazilian market-based. Jur 16. |
• | 15% of 10% of total adjusted revenues are Peruvian market-based. Jur 17. |
• | 15% of 10% of total adjusted revenues are Chilean market-based. Jur 18. |
• | 10% of 10% of total adjusted revenues are Argentinean market-based. Jur 19. |
• | 20% of 10% of total adjusted revenues are Paraguay market-based. Jur 20. |

FB 1: $.1B

• All of its revenues remain unaffected. All of its income is from sources within a jurisdiction (jur 21) other than the jurisdiction of residence of CFC 1 (owner of FB 1). any registered intercompany revenues are less than 15% of its total revenues during the current year.

The resultant of the applying of the new revenue sourcing rules are as follows:

Step 4: Adjusted Revenues Allocation to Parties (referred herein below as "Jurisdiction")

MNE A: $10.52B of Sourced Adjusted Revenues

• | U.S. - Jur A. = $7.36989B |
• | Canada - Jur B = $2.1056B |
• | Mexico - Jur C = $1.0528B |

CFC 1: $4.1696B of Adjusted Revenues

• | Ireland - Jur 1 = $.8339B |
• | France - Jur 2 = $.8339B |
• | England - Jur 3 = $.8339B |
• | Germany - Jur 4 = $.8339B |
• | Russia - Jur 5 = $.8339B |

CFC 2: $2.084817B of Adjusted Revenues

• | China - Jur 6 = $1.042417B. |
• | Japan - Jur 7 = $.2606B |
• | S. Korea - Jur 8 = $.2606B |
• | India - Jur 9 = $.2606B |
• | Singapore - Jur 10 = $.2606B |

CFC 3: $1.146659B of Adjusted Revenues

• | South-Africa - Jur 11 = $.458663B |
• | Turkey market-based - Jur 12 = $.171998B |
• | Egypt - Jur 13 = $.171998B |
• | Israeli - Jur 14 = $.114665B |
• | Saudi Arabia - Jur 15 = $.229331B |

CFC 4: $1.9805B of Adjusted Revenues

• | Brazil - Jur 16 = $.792237B |
• | Peru - Jur 17 = $.29708B |
• | Chile - Jur 18 = $.29708B |
• | Argentinean - Jur 19 = $.19805B |
• | Paraguay - Jur 20 = $1.98059B |

FB 1: $.10424178B of Adjusted Revenues

• Nigeria - Jur 21 = $.10424178B

The jurisdictionally sourced revenues above sum up to a calculated adjusted revenues of $20.0142507B: a close approximation to our earlier calculated $20.014422B of adjusted revenues.

We noted, confirmed, and now conclude that all 21 jurisdictions have passed MLC's Part II Article 8 test. That is:

• For all jurisdictions with GDP equal to or greater than $40B, the sourced adjusted revenues were above $1M.
• And, for all jurisdictions with GDP less than $40B, the sourced adjusted revenues were above $.25M.
• Let's recall that we consider the $ 1 to be equivalent to the 1 EUR.

Now, let's calculate the Amount A's profits allocable to each jurisdiction involved:

Step 5: Adjusted Jurisdictional Elimination Profits

MNE A: $.36337B of "Regional" Elimination Profit

• | U.S. - Jur A. = $.254359B of sourced adjusted revenues |
• | Canada - Jur B = $.065406B |
• | Mexico - Jur C = $.043604B |

CFC 1: $.1439068B of "Regional" Elimination Profit

• | Ireland - Jur 1 = $.02878136B |
• | France - Jur 2 = $.02878136B |
• | England - Jur 3 = $.02878136B |
• | Germany - Jur 4 = $.02878136B |
• | Russia - Jur 5 = $.02878136B |

CFC 2: $.0719544B of "Regional" Elimination Profit

• | China - Jur 6 = $.03597699B. |
• | Japan - Jur 7 = $.008994B |
• | S. Korea - Jur 8 = $.008994B |
• | India - Jur 9 = $.008994B |
• | Singapore - Jur 10 = $.008994B |

CFC 3: $.039575B of "Regional" Elimination Profit

• | South-Africa - Jur 11 = $.01583001B |
• | Turkey market-based - Jur 12 = $.005936B |
• | Egypt - Jur 13 = $.005936B |
• | Israeli - Jur 14 = $.0039575B |
• | Saudi Arabia - Jur 15 = $.007915B |

CFC 4: $.068353B of "Regional" Elimination Profit

• | Brazil - Jur 16 = $.027341B |
• | Peru - Jur 17 = $.01025B |
• | Chile - Jur 18 = $.01025B |
• | Argentinean - Jur 19 = $.006835B |
• | Paraguay - Jur 20 = $.0136707B |

FB 1: $.00345133B

• Nigeria - Jur 21 = $.00345133B.

Note that this jurisdiction is disregarded as it considered an autonomous business exception. See Annex C, Section 5, Para 2(a)(i)&(ii).

The jurisdictional elimination profits above sum up to a calculated covered group elimination profit of $.69061053B: a close approximation to our earlier calculated $.69076445B of total covered group elimination profit. The exercise here was done in accordance with the MLC's Part III, Article 5, Para 1(a).

Step 6: Specified Jurisdiction Determination Test

After jurisdictional profit allocation, we seek to determine from our 21 jurisdictions involved, which out of them will meet the definition of "specified jurisdictions" within the meaning of Part IV's Article 10 (a).

Our Testing(s):

• ((Elimination profits of MNE A, CFC 1, CFC 2, & CFC 3) / Covered Group's total elimination profits) = 89.5828%.
• ((Elimination Profits Above + CFC 4's Brazil profits) / Covered Group's total elimination profits) = 93.54%.
• ((Elimination Profits Above + CFC 4's Peru's profits) / Covered Group's total elimination profits) = 95.02%.

Result(s):

• After the bullet point above, we stop; as we have determined that out of the 21 jurisdictions involved, jurisdictions tied to MNE A, CFC 1, CFC 2, CFC 3, and only CFC 4's Brazil and Peru ones are considered specified jurisdictions within the meaning of the MLC's Part IV, Article 10(a).
• For purposes of this exercise, we note that we consider the remaining jurisdictions to not meet the requirements of the MLC's Part IV, Article 10 (b) & (c). Therefore, remaining non-specified jurisdictions.

Now that we have reached the first step in determining both the preliminary jurisdictional elimination profits and the specified jurisdictions thereby concerned, we address the second step: testing each jurisdictional elimination profit to determine if it surpasses the de-minimis threshold as dictated in the MLC. See Part III, Article 5, Para 1(b).

Step 7: MDSH Excess Profits Test

The result of our fifth step's testing allows us to conclude that the jurisdictional elimination profits of most jurisdictions do not surpass the $50M threshold. In fact, all jurisdictions, except the U.S. ($254M) and Canada ($65M) pass the de-minimis threshold. Thus, the MDSH adjustment will only be applicable to the U.S. and Canada. Additionally, for this step, we have assumed that CFC 1's elimination profit calculated above and used for testing purposes included the "withholding tax upward adjustment" calculated earlier, as dictated by Part III, Article 5, Para 2(f)(ii).

Step 8: Jurisdictional MDSH Adjustment

Jurisdiction(s): United States

The entities and jurisdictions with profits in excess of de-minimis threshold will have those revenues measured against the higher of return on depreciation and payroll (referred herein below as "RODP") threshold and return on adjusted sourced jurisdictional revenues (referred herein after as "ROR Floor"). With this step's relevant data provided below, let's apply the texts.

1. Covered Group's Pillar One's Amount A's Adjusted Rev = $20.014422B
2. Covered group's depreciation and payroll are as follows:

Depreciation:

MNE A = $.51B | CFC 1 = $.12B | CFC 2 = $.14B | CFC 3 = $.17B | CFC 4 = $.16B.

Payroll:

MNE A = $.53B| CFC 1 = $.15B | CFC 2 = $.14B | CFC 3 = $.17B | CFC 4 = $.16B.

Elimination RODP = ((.1 * $20.014422B) / ((.51B + $.32B + $.14B + $.17B + $.16B) +($.53B + $.15B + $0.14B + $.17B + $.16B))) * (.7*($.51B + $.53B))

• RODP = (($2.0014422B)/(2.45)) *($.728B)
• RODP = .816915 * $.728B
• RODP MNE A (U.S. only / 70% revenues only)= $0.59471B

ROR Floor = 7.36989B * .03 = $.221096B

"Low Depreciation & Payroll Jurisdiction ("LDPJ")" Test:

• Step 1: Jurisdictional Ratio = ((.7*($.51B + $.53B))/ $7.36989B) = 9.878%
• Step 2: Covered Group Ratio = (((.51B + $.32B + $.14B + $.17B + $.16B)+($.53B + $.15B + $0.14B + $.17B + $.16B))/20.014422B) = 12.24117%
• Testing Result(s): 1. Per Part IV, Article 5, Para 2(e), the U.S. meets the definition of "Low Depreciation and Payroll jurisdiction".2. As such, it is required to used as “jurisdictional offset percentage", within the meaning of Part IV, Article 5, Para 2(d)(ii)(B), 35%. 3. Its adjusted jurisdictional excess profits, within the meaning of Part IV, Article 5, Para (2)(c)(ii), is $.549B: the higher of $.549B and $.221096B calculated above.4. The "jurisdictional offsetting profits", within the meaning of Part Iv, Article 5, Para 5(2)(b), is $.208149988B: the product of the RODP and the offset percentage.5. Thus, the marketing and distribution profits safe harbour adjustment is $.208149988B: the lower of "jurisdictional offsetting profits" or the "U.S. jurisdictional elimination profit amount". See the MLC's Part IV, Article 5, Para (2)(a). 6. The final newly allocated amount A profit to the U.S. jurisdiction under the MLC rules is $.0462090112B: MLC, Part IV, Article 5, Para 1.
• Based on the U.S. jurisdiction's RODP percentage results above, the U.S. falls in the Tier 2 jurisdiction bracket; this, according to the MLC's part IV, Article 11, Para 5(b).

Jurisdiction(s): Canada

1. Covered Group's Pillar One's Amount A's Adjusted Rev = $20.014422B
2. Covered group's depreciation and payroll are as follows:

Depreciation:

MNE A = $.31B | CFC 1 = $.12B | CFC 2 = $.14B | CFC 3 = $.17B | CFC 4 = $.16B.

Payroll:

MNE A = $.33B| CFC 1 = $.15B | CFC 2 = $.14B | CFC 3 = $.17B | CFC 4 = $.16B.

Elim Threshold RODP = ((.1 * $20.014422B) / ((.51B + $.32B + $.14B + $.17B + $.16B) +($.53B + $.15B + $0.14B + $.17B + $.16B))) * (.2*($.51B + $.53B))

• Elim Threshold RODP = (($2.0014422B)/(2.45))*($.208B)
• Elim Threshold RODP = .816915 * $.208B
• Elim Threshold RODP MNE A (Canada / 20% revenues only) = $0.16991B

ROR Floor = $2.1056B * .03 = $.063168B

"Low Depreciation & Payroll Jurisdiction ("LDPJ")" Test:

• Step 1: Jurisdictional Ratio = ((.2*($.51B + $.53B))/ $2.1056B) = 9.878419%
• Step 2: Covered Group Ratio = (((.51B + $.32B + $.14B + $.17B + $.16B) +($.53B + $.15B + $0.14B + $.17B + $.16B))/20.014422B) = 12.24117%

Testing Result(s):

1. Per Part IV, Article 5, Para 2(e), Canada meets the definition of "Low Depreciation and Payroll jurisdiction".

2. As such, it is required to use as “jurisdictional offset percentage", within the meaning of Part IV, Article 5, Para 2(d)(ii)(B), 35%.

3. Its adjusted jurisdictional excess profits, within the meaning of Part IV, Article 5, Para (2)(c)(ii), is $0.16991B: the higher of $0.16991B and $.063168B calculated above.

4. The "jurisdictional offsetting profits", within the meaning of Part Iv, Article 5, Para 5(2)(b), is $.059471B: the product of the RODP and the offset percentage.

5. Thus, the marketing and distribution profits safe harbour adjustment is $.059471B: the lower of "jurisdictional offsetting profits" or the "U.S. jurisdictional elimination profit amount". See the MLC's Part IV, Article 5, Para (2)(a).

6. The final newly allocated amount A profit to the Canadian jurisdiction under the MLC rules is $.005934B. MLC, Part IV, Article 5, Para 1.

Jurisdiction(s): Rest of Jurisdictions

The remaining jurisdictions have been allocated their respective amount A elimination profits. Which are lower than $50M. As such, they are not subject to the testing demonstrated above. This, in order to primarily obtain the jurisdictional MDSH adjustment. And, secondarily the final jurisdictional amount A elimination profit.

Step 9: Jurisdictional Tierinf for Double Taxation Relief Obligation Purposes.

We have obtained adjusted revenues and adjusted profits. We have allocated adjusted revenues and adjusted profits to each jurisdiction involved (16 new jurisdictions). Then, we have calculated, as applicable, the amount a's marketing and distribution profits safe harbour adjustment (recall: this was only applicable to the U.S. and Canada).

Now, for purposes of determining which jurisdiction(s) will carry the obligation to eliminate double taxation with respect to amount a relief amount, we calculated the RODP of each jurisdiction. MLC Part IV, Article 11, Para 5.

Adjusted Jurisdictional RODP Testing:

• Covered Group RODP = $4.7645B / 2.45 = 1.94469
• Covered Group Elim Threshold RODP = = ((.1 $20.014422B) / ((.51B + $.32B + $.14B + $.17B + $.16B) +($.53B + $.15B + $0.14B + $.17B + $.16B))) = 2.014422 / 2.45= 81.6915%
• Given that the covered group numbers calculated above do not allow us to properly classify our jurisdictions in appropriate tiers, we will assume the following: 1. That the covered group's RODP is 31.4576%. 2. And, that the covered group's Elim threshold RODP is 16.3383%.

The following represents the adjusted jurisdictional RODP of each jurisdiction:

• | U.S. - Jur A. = ($.254359B-.208149988B)/((.7*($.51B + $.53B)) = 6.347% |
• | Canada - Jur B = ($.065406B-$.059471B) / ((.2*($.51B + $.53B)) = 2.85288%|
• | Mexico - Jur C = $.043604B / ((.2*($.51B + $.53B)) = 41.1926% |
• | Ireland - Jur 1 = $.02878136B / ((.12B + .15B)*.2) = 53.298% |
• | France - Jur 2 = $.02878136B / ((.12B + .15B)*.2) = 53.298% |
• | England - Jur 3 = $.02878136B / ((.12B + .15B)*.2) = 53.298% |
• | Germany - Jur 4 = $.02878136B / ((.12B + .15B)*.2) = 53.298% |
• | Russia - Jur 5 = $.02878136B / ((.12B + .15B)*.2) = 53.298% |
• | China - Jur 6 = $.03597699B / ((.14B + .14B)*.5) = 25.69785% |
• | Japan - Jur 7 = $.008994B / ((.14B + .14B)*.125) = 6.4244625% |
• | S. Korea - Jur 8 = $.008994B / ((.14B + .14B)*.125) = 6.4244625% |
• | India - Jur 9 = $.008994B / ((.14B + .14B)*.125) = 6.4244625% |
• | Singapore - Jur 10 = $.008994B / ((.14B + .14B)*.125) = 6.4244625% |
• | South-Africa - Jur 11 = $.01583001B / ((.17B + .17B)*.4) = 11.6397132%|
• | Turkey market-based - Jur 12 = $.005936B / ((.17B + .17B)*.15) = 11.639% |
• | Egypt - Jur 13 = $.005936B / ((.17B + .17B)*.15) = 11.639% |
• | Israeli - Jur 14 = $.0039575B / ((.17B + .17B)*.10) = 11.639% |
• | Saudi Arabia - Jur 15 = $.007915B / ((.17B + .17B)*.20) = 23.2794% |
• | Brazil - Jur 16 = $.027341B / ((.17B + .17B)*.4) = 20.1036% |
• | Peru - Jur 17 = $.01025B / ((.17B + .17B)*.15) = 20.098% |
• | Chile - Jur 18 = $.01025B / ((.17B + .17B)*.15) = 20.098% |
• | Argentinean - Jur 19 = $.006835B / ((.17B + .17B) *.1) = 20.1029% |
• | Paraguay - Jur 20 = $.0136707B / ((.17B + .17B) *.2) = 20.1039% |

FB 1: $.00345133B

Nigeria - Jur 21 = $.00345133B.

Jurisdiction is disregarded as it considered an autonomous business exception. See Annex C, Section 5, Para 2(a)(i)&(ii).

Jurisdictional Results' Tiering:

Tier 1 - No jurisdiction meets the MLC's Part IV, Article 11, Para 5(a) test.

Tier 2 - Ireland, France, England, Germany, and Russia meet the MLC's Part IV, Article 11, Para 5(b) test.

Tier 3A - Only Mexico meets the MLC's Part IV, Article 11, Para 5(c) test.

Tier 3B - Saudi Arabia, Brazil, Peru, Chile, Argentina, and Paraguay meet the MLC's Part IV, Article 11, Para 5(a) test.

Step 10: Allocation of Obligation To Eliminate Double Taxation Related to Amount A

For purposes of step 5 of the exercise, we will simply highlight the references that dictate how to address the elimination of double taxation after having tiered the jurisdictions into tier relieving groups.

• For Tier 2 jurisdictions, one should follow the MLC's Part IV, Article 11, para (9) & Para (10).
• For Tier 3A jurisdictions, appropriate determination would follow MLC's Part IV, Article 11, para (11) & Para (12).
• For Tier 3B jurisdictions, appropriate determination would follow MLC's Part IV, Article 11, para (13) & Para (14).

Next, for purposes of this step, we also assume that the methos of relief of from double taxation applied by tiered parties ("jurisdiction") as defined above are in compliance with the provisions of the MLC's Part IV, Article 12, Para 1(a),1(b),1(c), Para 2, Para 3, Para 4, and Para 5. This, along with entire provisions of article 13 of part IV of the MLC.

Step 11: Conclusion / Benefits of Accurate Pillar One Calculation.

1. With an additional $.69076445B in excess profits reallocated to both old and new jurisdictions, if we estimate all new jurisdictions to have an effective tax rate of at least 17%, then the income tax paid on the newly allocated profits according to the MLC would be accounted for as "good covered taxes" (.6907445B -.208149B - .059471B) *.17 = $71.93M.
2. As noted above, given that 80% of 25% of our FIN 48 tax liability was created in the current year, abiding by the MLC's rules allows MNE A to address one of the main drivers of its FIN 48 tax - "the uncertainty around its revenues sourcing positions in each of the different regions of the world." Both during the year and on an onward basis. As such, the amount of FIN 48 taxes that switches from being disallowed deferred tax liability to allowed deferred tax liabilities under pillar two is .$2B = ($.250B * 80%). Here, the likelihood of payment of the $.2B in covered taxes to imposing jurisdictions is compliant with the OECD's Pillar two's art 4.4.4. Note that the remaining 20% can likely not become good covered taxes per art 4.4.6(b).
3. Lastly, based on the details provided above regarding the CFCs, in this exercise, CFC 3 is determined to be the Designated Payment Entity ("DPE"). Please see Pg. 272. para 1163 thru 1169, example 1, box 23 & Annex B, Section 3, para 1(a) & (b).

It is both my appetite for understanding the complex global taxation matters of multinational enterprise groups, and my dedication toward my journey to becoming a shrewd, prudent, and sound multi-disciplinary (three disciplines in one: tax accounting, tax law, and transfer pricing) practitioner that has led me to design this practical-demonstration-of-interplay-between-domestic-tax-regimes-and-the-rules' article.

As such, I hope you, my audience, have enjoyed or will enjoy walking through this article. And, I look forward to striking mutually-beneficial discussions with you or receiving your feedback in the comment section below.

In the meantime, stay well. Stay safe. Till next time!

Franck Yannick Fassu.