Pillar one and mobility electrónico a truly global solution? Svetislav V. Kostić, Aitor Navarro
By: Kostic, Svetislav V
.
Contributor(s): Navarro, Aitor.
Material type: 
ArticleSubject(s): FISCALIDAD INTERNACIONAL | PRIMER PILAR (OCDE)Online resources: Click here to access online
In:
Intertax v. 51, Issue 12, December 2023, p. 840-850Summary: Mobility should be at the core of the reallocation of taxing rights debate. With such a premise in mind, this contribution addresses this issue within Pillar One in its two components: the apportionment of taxing rights to market jurisdictions on residual profits of the most significant MNEs worldwide (Amount A) and the standardization of the remuneration of related party distributors that perform baseline marketing and distribution activities in market jurisdictions (Amount B). The aim is to show that not only the mobility of individuals but also that of MNE structures when deciding on their presence in market jurisdictions are relevant in building new paradigms on the allocation of taxing rights at a cross-border level through the specific impact of the said OECD proposal. Even if Pillar One seems doomed to fail, lessons learned from its design and its specific impact on mobility matters should inform further developments in reshaping international taxation.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | OP 2141/2023/12-4 (Browse shelf) | Available | OP 2141/2023/12-4 |
Browsing IEF Shelves Close shelf browser
| No cover image available | No cover image available | No cover image available | No cover image available | No cover image available | No cover image available | No cover image available | ||
| OP 2141/2023/12-1 Would Pillar One fix the broken system? | OP 2141/2023/12-2 Pillar one and alchemy | OP 2141/2023/12-3 Principles justifying the reallocation of taxing rights to market jurisdictions | OP 2141/2023/12-4 Pillar one and mobility | OP 2141/2023/12-5 Critical review of the atad implementation | OP 2141/2023/12-6 The 1963 OECD model tax convention | OP 2141/2023/1-3 Economic substance for holding companies in the post- BEPS world and after recent ECJ case-law |
Mobility should be at the core of the reallocation of taxing rights debate. With such a premise in mind, this contribution addresses this issue within Pillar One in its two components: the apportionment of taxing rights to market jurisdictions on residual profits of the most significant MNEs worldwide (Amount A) and the standardization of the remuneration of related party distributors that perform baseline marketing and distribution activities in market jurisdictions (Amount B). The aim is to show that not only the mobility of individuals but also that of MNE structures when deciding on their presence in market jurisdictions are relevant in building new paradigms on the allocation of taxing rights at a cross-border level through the specific impact of the said OECD proposal. Even if Pillar One seems doomed to fail, lessons learned from its design and its specific impact on mobility matters should inform further developments in reshaping international taxation.
There are no comments for this item.