Case Study Analysis of the OECD Pillar One and Pillar Two Allocations to Developing Countries

Abstract

In this article, the author considers whether the taxable income allocation under the OECD's Pillar One and Pillar Two proposals can generate consistent tax revenue for developing countries to fund their sustainable development. The analysis adopts a case-study approach that simulates the operation of the OECD proposals under three profit-shifting schemes.

Full-text Paper: https://doi.org/10.59403/2kd6zgk

Keywords: Pillar 1 (OECD), Unified Approach (OECD), Pillar 2 (OECD), GloBE (OECD), allocation of taxing rights, developing countries, profit shifting