The International Tax Regime at 100: Reflections on the OECD's BEPS Project

12 Pages Posted: 7 Sep 2021 Last revised: 14 Oct 2021

Date Written: August 22, 2021

Abstract

This essay will consider the outcome of Pillars One and Two in light of the history of international taxation since the foundation of the international tax regime in 1923. Specifically, it will consider how Pillar One fits with efforts to redefine the source of active income in light of the digital revolution, and the ways in which Pillar Two implements the single tax principle, which can be traced back to the first model treaty from 1927. Both of those ideas were already articulated and developed in my own early writing on international taxation from the 1990s, when the Internet was in its infancy.

Keywords: BEPS 2.0, Pillar One, Pillar Two

JEL Classification: H24

Suggested Citation

Avi-Yonah, Reuven S., The International Tax Regime at 100: Reflections on the OECD's BEPS Project (August 22, 2021). U of Michigan Law & Econ Research Paper No. 21-020, Available at SSRN: https://ssrn.com/abstract=3908575 or http://dx.doi.org/10.2139/ssrn.3908575

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Do you have a job opening that you would like to promote on SSRN?

Paper statistics

Downloads
553
Abstract Views
1,170
rank
74,349
PlumX Metrics