The Ability to Pay and Economic Allegiance

Jazyk:	angličtina
Rok vydání:	2021
Předmět:	Automated digital services UN proposals on shared taxing rights Economic allegiance Ability to pay principle Pillar one blueprint UN model tax convention Allocation of taxing rights Single tax principle Inclusive framwork OECD model tax convention Inclusive framework
Zdroj:	Intertax. 49(8-9):636-655
ISSN:	0928-2750 0165-2826
Popis:	The OECD/G20 Inclusive Framework and the UN are working intensively on how to change the allocation of taxing rights to cross border income and to adapt the international tax regime to the digitalization of the economy. A stated aim is that more taxing rights should be allocated to the market states. However, during the process it has become clear that it remains uncertain why the allocation of taxing rights should be changed. In this article, it is argued that the allocation should continue to be justified by the principle of economic allegiance in accordance with the ability of the MNEs to pay taxes. On this basis, it is analysed whether the following three measures are justifiable: the new nexus under the Pillar One Blueprint, the inclusion of software in the definition of royalties in the UN Model Tax Convention and the implementation of a shared taxing right for automated digital services in the UN Model Tax Convention.
Databáze:	OpenAIRE
Externí odkaz:	https://explore.openaire.eu/search/publication?articleId=dris___00958::9651bd24545c6ac9228ea50bf4132fc4 https://research.cbs.dk/en/publications/2e2e1936-e43e-45bb-a230-304c2ad9fe1a Zobrazit plný text záznamu