Comparing Proposals to Tax Some Profit in the Market Country

Abstract

This article compares and contrasts three specific proposals that allocate taxing rights to market countries: (i) the OECD's "Unified Approach" (Pillar One); (ii) the United Nations' "Article 12B"; and (iii) Devereux et al.'s "residual profit allocation by income". The article aims to identify the similarities and differences between these proposals and their consequent strengths and weaknesses. More specifically, it has two objectives. First, it aims to identify the strengths and weaknesses that are particular to each proposal, distinguishing 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 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.

Full-text Paper

Keywords: allocation of taxing rights, Unified Approach (OECD), Pillar 1 (OECD), UN Model, allocation of profits, avoidance of double taxation

JEL Classification: K33, K34