The Resource Distributive profit allocation rules : a new approach for an old problem

Distributive profit allocation rules : a new approach for an old problem

Label
Distributive profit allocation rules : a new approach for an old problem
Title
Distributive profit allocation rules : a new approach for an old problem
Creator
Subject
Language
eng
Summary
The article argues that the OECD in its recently announced Unified Approach (UA) contained in Pillar I did not address the underlying problems that actuated the BEPS Program in the first place. The author believes that tax policy requires addressing these fundamental issues and agreement on fundamental justice principles underlying international tax law, principles that would best be reflected in new nexus and profit allocation rules based on factors of distributive justice. First, the article explains the origin of the international tax system in relation to the residence-source dichotomy and the taxation of business profits, accentuating its lack of inter-nation equity considerations and technical shortcomings. Further, it reviews the OECD's UA proposal for reforming the international tax system as it currently stands, emphasizing its lack of moral foundations. Furthermore, it identifies a philosophical framework on which to ground international tax law and proposes the bases for new nexus and profit allocation rules coherent with such a framework
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 49 (2021), no. 2 ; p. 144-165
http://library.link/vocab/creatorName
Mahu Martínez, P.A
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • allocation of profits
  • nexus
  • Pillar 1 (OECD)
  • Unified Approach (OECD)
  • international taxation
  • redistribution principle
Label
Distributive profit allocation rules : a new approach for an old problem
Instantiates
Publication
Label
Distributive profit allocation rules : a new approach for an old problem
Publication

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