The ability to pay and economic allegiance justifying additional allocation of taxing rights to market states Louise Fjord Kjaersgaard
By: Kjaersgaard, Louse Fjord
.
Material type: 
ArticlePublisher: 2021Subject(s): OPERACIONES TRANSFRONTERIZAS | ECONOMÍA DIGITAL | FISCALIDAD INTERNACIONAL | PRIMER PILAR (OCDE) | MODELO DE CONVENIO OCDE
In:
Intertax v. 49, Issues 8-9, August/September 2021, p. 636-655Summary: The OECD/G20 Inclusive Framework and the UN are working intensively on how to change the allocation of taxing rights to cross border income and to adapt the international tax regime to the digitalization of the economy. A stated aim is that more taxing rights should be allocated to the market states. However, during the process it has become clear that it remains uncertain why the allocation of taxing rights should be changed. In this article, it is argued that the allocation should continue to be justified by the principle of economic allegiance in accordance with the ability of the MNEs to pay taxes. On this basis, it is analysed whether the following three measures are justifiable: the new nexus under the Pillar One Blueprint, the inclusion of software in the definition of royalties in the UN Model Tax Convention and the implementation of a shared taxing right for automated digital services in the UN Model Tax Convention.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2021/8/9-4 (Browse shelf) | Available | OP 2141/2021/8/9-4 |
Browsing IEF Shelves Close shelf browser
Disponible también en formato electrónico.
Resumen.
The OECD/G20 Inclusive Framework and the UN are working intensively on how to change the allocation of taxing rights to cross border income and to adapt the international tax regime to the digitalization of the economy. A stated aim is that more taxing rights should be allocated to the market states. However, during the process it has become clear that it remains uncertain why the allocation of taxing rights should be changed. In this article, it is argued that the allocation should continue to be justified by the principle of economic allegiance in accordance with the ability of the MNEs to pay taxes. On this basis, it is analysed whether the following three measures are justifiable: the new nexus under the Pillar One Blueprint, the inclusion of software in the definition of royalties in the UN Model Tax Convention and the implementation of a shared taxing right for automated digital services in the UN Model Tax Convention.
Click on an image to view it in the image viewer
There are no comments for this item.