The OECD has published a Model Competent Authority Agreement to facilitate the implementation of its political commitment on Amount B of Pillar One.
Tax jurisdictions can use the Model to implement the political commitment where there is a tax treaty in place. Entering into an Agreement is optional for tax jurisdictions.
The absence of such an agreement does not, in itself, impede the implementation of the political commitment, which could be implemented by tax jurisdictions through other means in light of their legal and administrative systems.
Inclusive Framework members that wish to extend the political commitment to tax jurisdictions not included in the list of covered tax jurisdictions may also use the Model.
The text of the Model should be considered as suggested language only, and tax jurisdictions are free to modify the specific language in their bilateral negotiations.