000			02015nab a2200241 c 4500
999			_c142289 _d142289
003			ES-MaIEF
005			20210824122133.0
007			ta
008			200805t2020 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041			_aeng
100	1		_966111 _aBuriak, Svitlana
245		2	_aA new taxing right for the market jurisdiction _bwhere are the limits? _c Svitlana Buriak
260			_c2020
500			_aResumen.
520			_aThis article discusses which business models should fall under the scope of the new taxing right of the market state proposed in the OECD Secretariat's Proposal for a Unified Approach. In the first section, it contends that the proposal for the new taxing right should be built upon a solid principle-based foundation. Given that 'value creation' is a subjective arbitrary concept, it cannot be relied upon when attributing taxing rights to the market state. For this reason, the author argues that the allocation of taxing rights to the market jurisdiction is justified only when the market jurisdiction is regarded as the place of origin of the income where wealth is produced. In the second section, the article analyses the business models in which customers take part in the income - generation process of multinational enterprises (MNEs) and thereby establish an economic link between the profits of highly-digitalized MNEs and market states. In that regard, the article contributes to the discussion on what 'businesses in scope' under the Unified Approach should include. Last but not least, the article considers the limitations of the new nexus rule based on a threshold of revenue and what other alternative nexus solutions could be developed.
650		4	_944303 _aFISCALIDAD INTERNACIONAL
650		4	_aCREACIÓN DE VALOR _967011
650		4	_aTIPO MÍNIMO GLOBAL _967681
650		4	_aCONFLICTOS JURISDICCIONALES _940558
773	0		_9162422 _oOP 2141/2020/3 _tIntertax _w(IEF)55619 _x 0165-2826 _gv. 48, issue 3, March 2020, p. 301-316
942			_cART