Behavioral incentives under amount A law of unintended consequences redux by Kartikeya Singh
By: Singh, Kartikeya
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Material type: 
ArticlePublisher: 2024Subject(s): AMOUNT A (PRIMER PILAR, OCDE) | TRATADOS INTERNACIONALES | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO
In:
Tax Notes International v. 115, n. 10, September 2 2024, p. 1469-1486Summary: Kartikeya Singh is a principal in the transfer pricing practice of PwC’s Washington National Tax Services. He thanks Stewart Brant, Peter Merrill, W. Joe Murphy, and Pat Brown for their review and comments In this article, Singh uses a hypothetical example to explain how behavioral incentives created by pillar 1 amount A rules could influence in-scope companies to relocate personnel and physical capital away from headquarter jurisdictions to low-tax investment hubs. The views expressed herein are solely those of the author and do not necessarily reflect those of PwC. All errors and views are those of the author and should not be ascribed to PwC or any other person.
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Kartikeya Singh is a principal in the transfer pricing practice of PwC’s Washington National Tax Services. He thanks Stewart Brant, Peter Merrill, W. Joe Murphy, and Pat Brown for their review and comments In this article, Singh uses a hypothetical example to explain how behavioral incentives created by pillar 1 amount A rules could influence in-scope companies to relocate personnel and physical capital away from headquarter jurisdictions to low-tax investment hubs. The views expressed herein are solely those of the author and do not necessarily reflect those of PwC. All errors and views are those of the author and should not be ascribed to PwC or any other person.
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