Disruptive profit allocation methods for disruptive businesses?! (part 2)

Resource Information

The work Disruptive profit allocation methods for disruptive businesses?! (part 2) represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Disruptive profit allocation methods for disruptive businesses?! (part 2)

Creator

• De Baets, S
• Smolkowska, A

Subject

• OECD
• Pillar 1 (OECD)
• Pillar 2 (OECD)
• UN
• Unified Approach (OECD)
• GloBE Proposal (OECD)
• arm's length principle
• marketing intangibles
• significant economic presence
• user participation
• allocation of profits
• IMF

Language

eng

Summary

In February 2019, the OECD launched a Consultation Document on the digitalisation of the economy indicating a way forward based on two pillars (revised nexus and profit allocation rules, and global anti-base erosion approaches), followed by a Public Consultation on 15 and 16 March 2019. Finally, the OECD published a Programme of Work to develop a consensus solution to the tax challenges arising from the digitalisation of the economy on 31 May 2019. The first part of this article 1 discussed the different approaches for taxing the digitalised economy embedded in those documents. In this part II, the authors critically analyse the approaches put forward by the OECD as well as some alternatives that other organisations have suggested. In their conclusion, the authors indicate some recommendations for the negotiators sitting around the big inclusive framework table

Citation source

In: TPI - Transfer Pricing International. - Wien. - Vol. 3 (2019), no. 6 ; p. 324-334

Geographic coverage

International

Language note

English