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The deceptive allure of taxing "residual profits" electrónico Stephen E. Shay

By: Shay, Stephen E .

Material type: Article

ArticlePublisher: 2021Subject(s): IMPUESTO DE SOCIEDADES

| BENEFICIOS

| EMPRESAS MULTINACIONALES

| PRIMER PILAR (OCDE)

In: Bulletin for International Taxation v. 75, n. 11/12, 2021, p. 527-532Summary: This article outlines the traditional justifications for a residual profits business tax base and evaluates its role in the OECD/G20 Pillar One proposal to allocate income to market countries. The article concludes that basing the allocation of profits to market countries on multinationals' residual profits would be inferior to allocating a portion of total corporate profits.

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Item type	Current location	Home library	Call number	Status	Date due	Barcode
Recursos electrónicos	IEF	IEF	BIT/2021/11/12-2 (Browse shelf)	Available		BIT/2021/11/12-2

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Previous	BIT/2021/11/12-17 What can we learn from the history of Article 21 of the OECD Model?	BIT/2021/11/12-18 Proposal for a reform of Article 21 of the OECD Model	BIT/2021/11/12-19 What is a "tax paid in that other state" under Article 23 of the OECD Model?	BIT/2021/11/12-2 The deceptive allure of taxing "residual profits"	BIT/2021/11/12-20 The interpretation of tax treaties	BIT/2021/11/12-21 Interpretation of tax treaties and the decisions of foreign tax courts as a "subsequent practice" under Articles 31 and 32 of the Vienna Convention on the Law of Treaties (1969)	BIT/2021/11/12-22 International investment agreements and the international tax system	Next

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Resumen.

This article outlines the traditional justifications for a residual profits business tax base and evaluates its role in the OECD/G20 Pillar One proposal to allocate income to market countries. The article concludes that basing the allocation of profits to market countries on multinationals' residual profits would be inferior to allocating a portion of total corporate profits.

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The deceptive allure of taxing "residual profits" electrónico Stephen E. Shay

By: Shay, Stephen E.

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By: Shay, Stephen E .