Comparing proposals to tax some profit in the market country

This paper compares and contrasts three specific proposals that allocate taxing rights to market countries: the OECD’s “Unified Approach” (“Pillar One”), the United Nations’ “Article 12 B”; and Devereux et al.’s “Residual Profit Allocation by Income”. It aims to identify the similarities and differe...

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Main Authors: Vella, J, Collier, R, Devereux, M
Format: Journal article
Language:English
Published: Stichting Internationaal Belasting Documentatie Bureau 2021
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author Vella, J
Collier, R
Devereux, M
author_facet Vella, J
Collier, R
Devereux, M
author_sort Vella, J
collection OXFORD
description This paper compares and contrasts three specific proposals that allocate taxing rights to market countries: the OECD’s “Unified Approach” (“Pillar One”), the United Nations’ “Article 12 B”; and Devereux et al.’s “Residual Profit Allocation by Income”. It aims to identify the similarities and differences of these proposals, and their consequent strengths and weaknesses. More specifically, the paper has two objectives. First, we aim to identify strengths and weaknesses that are particular to each proposal. We distinguish between features that are inherent to each proposal (that cannot be altered without altering its fundamental nature) and those that are not inherent (that can be altered without altering its fundamental nature). This exercise lays the foundations for the second objective: to show how these proposals can be improved by drawing on the most useful features of each other, or how alternative proposals can be designed by combining these features.
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spelling oxford-uuid:c07176c1-45e6-40aa-a8ad-f7518500a8812022-03-27T05:54:20ZComparing proposals to tax some profit in the market countryJournal articlehttp://purl.org/coar/resource_type/c_dcae04bcuuid:c07176c1-45e6-40aa-a8ad-f7518500a881EnglishSymplectic ElementsStichting Internationaal Belasting Documentatie Bureau2021Vella, JCollier, RDevereux, MThis paper compares and contrasts three specific proposals that allocate taxing rights to market countries: the OECD’s “Unified Approach” (“Pillar One”), the United Nations’ “Article 12 B”; and Devereux et al.’s “Residual Profit Allocation by Income”. It aims to identify the similarities and differences of these proposals, and their consequent strengths and weaknesses. More specifically, the paper has two objectives. First, we aim to identify strengths and weaknesses that are particular to each proposal. We distinguish between features that are inherent to each proposal (that cannot be altered without altering its fundamental nature) and those that are not inherent (that can be altered without altering its fundamental nature). This exercise lays the foundations for the second objective: to show how these proposals can be improved by drawing on the most useful features of each other, or how alternative proposals can be designed by combining these features.
spellingShingle Vella, J
Collier, R
Devereux, M
Comparing proposals to tax some profit in the market country
title Comparing proposals to tax some profit in the market country
title_full Comparing proposals to tax some profit in the market country
title_fullStr Comparing proposals to tax some profit in the market country
title_full_unstemmed Comparing proposals to tax some profit in the market country
title_short Comparing proposals to tax some profit in the market country
title_sort comparing proposals to tax some profit in the market country
work_keys_str_mv AT vellaj comparingproposalstotaxsomeprofitinthemarketcountry
AT collierr comparingproposalstotaxsomeprofitinthemarketcountry
AT devereuxm comparingproposalstotaxsomeprofitinthemarketcountry