5 to mention that the quantum of Amount A will not be very contentious given the formulaic nature of its calculation, at least in cases with no financial segmentation. In contrast, there may be challenges and potential disputes in the application of sourcing rules for the distribution of Amount A, as well as for the selection of the paying entities and the jurisdiction in charge of relieving double taxation. The general idea is that each Multinational Entity(MNE) covered by Amount A will file a Country by Country report(CBC) in the Ultimate Parent Entity(UPE) jurisdiction and will prepare an Amount A proposal for the UPE to review. This UPE will finalize the proposal for Amount A determination and distribution as well as the identification of paying entities and the amount of residual profit allocated to them, based on the taxpayer proposal, the information submitted in the CBC and any additional information provided by the taxpayer. This proposal may be reviewed by a panel composed by a limited number of Competent Authorities(CAs) representing relevant jurisdictions(the“Review Panel”). It is probable that jurisdictions that are not represented in the panel will still get an opportunity to present written objections/observations to the UPE proposal, which the Review Panel will examine before issuing a decision to accept the UPE proposal, or an alternative proposal. It is important to mention that the Secretariat envisions a review mechanism whenever the panel has been unable to reach an agreement on any of the features of Amount A or if an interested jurisdiction that is not represented on the panel disagrees with the outcome of the Review Panel. In this case, the competing proposals will be submitted to a second panel(the“Determination Panel”), which can bring together competent authorities and independent members. The panel composition and mechanisms for nomination are still to be decided. The decision of this panel is to be binding upon all jurisdictions interested in Amount A, even if they were not directly represented on the panel, although the probability of sending written objections and observations to the panel still exists. It is important to note that jurisdictions that believe they are entitled to receive a portion of Amount A, but are not included in the proposal approved by the Determination Panel, will still be bound by this decision. The presence of the MNE in this mechanism was also granted in the July agreement, but it is unclear if they can be represented by law firms before the panel or if they can just accompany the UPE jurisdiction to answer questions from the panel regarding the proposal. It is safe to assume, however, that MNEs will retain law firms and accounting firms for the preparation of their CBC documentation and the initial Amount A proposal. Given that in many cases the IRS will act as the UPE administration,11 and given the IRS MAP procedure, these resources will almost certainly be used by the IRS in the preparation of its position in the review and determination panels, even if the MNE is not called for questioning. There has not been a public statement on the publicity and transparency of the prevention panels. 11 See Eden, L.(2021). Taxing The Top 100—Part 1: Who’s In, Who’s Out?. Available at https://news.bloombergtax.com/daily­tax-report/taxing-the-top-100-part-1-whos-in-whos-out.(last accessed on 21.2.2022)