The Resource The OECD Unified Approach : understanding the real deal for market countries

The OECD Unified Approach : understanding the real deal for market countries

Label
The OECD Unified Approach : understanding the real deal for market countries
Title
The OECD Unified Approach : understanding the real deal for market countries
Creator
Subject
Language
eng
Summary
The OECD Unified Approach under Pillar One deviates from the existing international business tax rules in many aspects. First, it extends the right to tax business profits on the basis of mere sales in addition to the existing "physical presence" nexus rule. Second, the income allocation rules go beyond the arm's length principle of transfer pricing rules, as well as beyond the transfer pricing approach to the formulary apportionment method in respect of allocating profits to market countries. Third, it recognizes demand-side factors, represented by sales, alongside supply-side factors for the allocation of business profits. However, the proposal raises serious doubts as far as the effective allocation of business profits to market countries is concerned. The scope of this article is to find out whether the proposed profit allocation rules under the OECD Unified Approach are effective in allocating income to market countries. As several attributes of the proposals are still under discussion, it is important to flag some of the concerns at this stage
Citation source
In: International Tax Studies (ITAXS). - Amsterdam. - Vol. 4 (2021), no. 5 ; 8 p
http://library.link/vocab/creatorName
  • Das, P
  • Rizzo, A
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • Unified Approach (OECD)
  • Pillar 1 (OECD)
  • nexus
  • arm's length principle
  • transfer pricing
  • nexus
  • allocation of profits
Label
The OECD Unified Approach : understanding the real deal for market countries
Instantiates
Publication
Label
The OECD Unified Approach : understanding the real deal for market countries
Publication

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