We commend the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of multinational enterprises’ business models and the evolution of cross-border ecommerce. Our comments and recommendations are submitted in an academic capacity and do not represent an official statement or…
In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint‘ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from digitisation. The Unified Approach (UA), which is the basis of the Blueprint, is intended to complement the existing system of corporate income taxation….
1. Introduction The Pillar Two Report[1] (the “Report”) which contains the Global Minimal Tax (the “GloBE tax”) proposal has recently been on the top of discussions both in the academic and practice world. While the proposals objective is debatable[2], the blueprint contains dozens of new rules, exceptions and mechanisms which may possibly complicate life not…
Since the OECD introduced its Global Anti-Base Erosion Proposal (GLoBE) in early 2019 as the second pillar of the ongoing search for a solution to the tax challenges of the Digitalisation of the economy, the goal of GloBE seems to be moving. On the one hand, already the name suggests that the proposal for a…
1. Introduction The ability to stimulate economic activity and to attract foreign capital and investments through national tax policies has been known for many centuries. It was in the middle of the eighteenth century that the Russian Empress – Catherine the Great – granted to “[…] Foreigners that have settled themselves in Russia to erect…
Purpose of the blog The purpose of the blog, which is slightly futuristic, is to discuss whether countries will still compete with one another to attract activities in their jurisdiction post-Pillar II implementation. State sovereignty and Tax Competition A sine qua non condition for the existence of international tax competition is the opportunity to transfer capital…
