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Erscheinungsjahr: 
2022
Schriftenreihe/Nr.: 
Research Paper No. 161
Verlag: 
South Centre, Geneva
Zusammenfassung: 
The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be developing countries, and Pillar Two is instituting a global minimum tax. The Pillar One solution, known as Amount A, will be codified into a Multilateral Convention (MLC) and is expected to be placed before countries for signature in early 2023. The solution ushers in a new paradigm in the taxation of multinational enterprises but has immense complexity and likely minimal revenue gains for most developing countries. It will also require them to give up the right of unilateral tax measures on all out-of-scope companies, meaning they will only be able to tax the fewer than 100 companies likely to be in-scope, if at all. The decision to sign or not is thus a historic one, as it will lock developing countries into a constricted new framework, at a time when revenue needs are especially critical to recover the economies from COVID-19 in the context of a turbulent state of the global economy. However, the United Nations too has a solution, known as Article 12B. This operates in a different manner and is a minor modification to the existing decentralized international tax system which is based on bilateral tax treaties, and which developing countries are more familiar with. It is also likely to generate far higher revenues than Amount A, and does not restrict any of their sovereign taxing rights. This Research Paper assesses the various implications for developing countries from adopting the OECD's or the United Nations's respective solutions and concludes with a possible global South response to the Two Pillar solution.
Schlagwörter: 
Amount A
Article 12B
Automated Digital Services (ADS)
Base Erosion and Profit Shifting Project (BEPS)
Bilateral Tax Treaties
Digital Economy
Digital Service Taxes (DSTs)
Digital Tax
Digital Taxation
Double Taxation
Global Minimum Tax Rate
Global Tax
Global Taxation
Group of 20 (G-20)
Group of 7 (G-7)
Group of 77 and China (G-77 and China)
Group of Twenty-Four (G-24)
Illicit Financial Flows (IFFs)
Inclusive Framework
International Tax
International Tax Cooperation
International Taxation
Multinational Enterprises (MNEs)
Organisation for Economic Co-operation and Development (OECD)
Pillar One
Pillar Two
Tax
Tax Cooperation
Tax Law
Tax Policy
Tax Reform
Taxation
Taxing Rights
The Multilateral Convention (MLC)
Two Pillar Solution
UN Model Tax Convention
UN Tax Committee
United Nations (UN)
Dokumentart: 
Research Report
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