Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/270381 
Year of Publication: 
2022
Series/Report no.: 
Research Paper No. 156
Publisher: 
South Centre, Geneva
Abstract: 
In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve review of any information that taxpayers provide to tax authorities. Our research demonstrates that the comparative revenue effects of the Amount A and Article 12B taxation regimes largely depend on (a) design details of the Article 12B regime, (b) whether the country hosts headquarters of MNEs that may be in scope of Amount A or Article 12B taxation, and (c) what relief from double taxation, if any, the country will grant to domestic taxpayers subject to taxation under either the Amount A or Article 12B regimes.
Subjects: 
African Union (AU)
Amount A
Article 12B
Automated Digital Services (ADS)
Base Erosion and Profit Shifting Project (BEPS)
Coalition for Dialogue on Africa (CODA)
Digital Economy
Digital Tax
Digital Taxation
Double Taxation
Global Tax
Global Taxation
Inclusive Framework
International Tax
International Tax Cooperation
International Taxation
Multinational Enterprises (MNEs)
Organisation for Economic Co-operation and Development (OECD)
Pillar One
South Centre Member States
Tax
Tax Cooperation
Tax Law
Tax Policy
Tax Reform
Taxation
Taxation in Developing Countries
Two Pillar Solution
UN Model Double Taxation Convention
United Nations Committee of Experts on International Cooperation in Tax Matters (UNTC)
Document Type: 
Research Report
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