Act of Creation: The OECD/G20 Test of “Value Creation” as a Basis for Taxing Rights and Its Relevance to Developing Countries

30 Pages Posted: 11 Jun 2020

Date Written: November 20, 2018

Abstract

This paper examines the use of the “value creation” concept that plays a central role in current OECD/G20 and European Union taxation work as a way of determining the taxation rights of countries, especially in the increasingly digitalised economy. It examines the likelihood of a consensus on whether it is an appropriate test, particularly with a view to the interests of developing countries. It also notes the need for such countries to ensure that their “policy space” in corporate taxation that is based on the place of consumption is not unduly limited by these developments

Keywords: BEPS, Base Erosion and Profit Shifting, developing countries, digital economy, multinationals, policy space, taxation of multinationals, tax treaties, transfer pricing, value creation

Suggested Citation

Lennard, Michael, Act of Creation: The OECD/G20 Test of “Value Creation” as a Basis for Taxing Rights and Its Relevance to Developing Countries (November 20, 2018). Transnational Corporations Journal, Vol. 25, No. 3, 2018, Available at SSRN: https://ssrn.com/abstract=3621967

Michael Lennard (Contact Author)

United Nations ( email )

New York, NY 10017
United States

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