Recommendation 19

Pillar One will operate within a multilateral administrative framework, with the emphasis on international cooperation. This will be very different to how HMRC currently ensures compliance with its tax regime.58 Getting 140 tax jurisdictions to agree on a framework for administering the new system will be a key challenge, but it may be even more of a challenge for some jurisdictions to then operate the system as intended. HMRC and HM Treasury acknowledged that work will be needed to increase the capacity of some 50 Q 37 51 C&AG’s Report, figure 13 52 Qq 49–51 53 Qq 34, 56 54 Qq 65–68, 70–75 55 Q 69 56 Qq 38, 39 57 Qq 82, 84 58 Q 56 14 The Digital Services Tax jurisdictions, while pointing out that the cooperation of some jurisdictions (such as those where Pillar One payers are headquartered or those that will be required to reallocate tax receipts under Pillar One) will be more important than others.59