The Resource The OECD "unified approach" : have the cards been reshuffled?

The OECD "unified approach" : have the cards been reshuffled?

Label
The OECD "unified approach" : have the cards been reshuffled?
Title
The OECD "unified approach" : have the cards been reshuffled?
Creator
Subject
Language
eng
Summary
In the course of the last years, the OECD extensively dealt with tax issues generated by the increasing digitalisation of business models. While the focus on BEPS action 1 was clearly on the taxation of "digital business", the OECD constantly enlarged the potential scope of its contemplations via "digitalised businesses" and finally ended up with a focus on "consumer-facing businesses" in the recent Secretariat Proposal of a "Unified Approach" under Pillar One. Accordingly, it can be reasonably concluded already from a prima vista perspective that the proposal presented by the OECD Secretariat is far-reaching and could be applicable for all businesses, since - at the end of the day - all businesses are eventually intended to be consumer-facing. On the basis of the far-reaching scope, the OECD proposed a new sales-based nexus in order to overcome the pitfalls of the currently applicable (and to a certain extent outdated) concept of permanent establishments, which is solely based on a certain degree of physical presence in a host state. Finally, based upon the scope and nexus, the market jurisdictions should (ideally) profit from the proposal, as those states are intended to be allocated (additional) profits based on a formulaic approach that would work in parallel to the current arm's length approach. This paper is meant to illustrate the rationale of the Unified Approach and is based on the comments of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU Vienna submitted during the course of the OECD public consultation
Citation source
In: TPI - Transfer Pricing International. - Wien. - Vol. 3 (2019), no. 6 ; p. 312-323
http://library.link/vocab/creatorName
  • Petruzzi, R
  • Holzinger, R
  • Screpante, M.S
  • Buriak, S
  • Cardoso, G. Capristano
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • Unified Approach (OECD)
  • Pillar 1 (OECD)
  • digital economy
  • arm's length principle
  • nexus
  • value creation
  • allocation of profits
Label
The OECD "unified approach" : have the cards been reshuffled?
Instantiates
Publication
Label
The OECD "unified approach" : have the cards been reshuffled?
Publication

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