Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/270392 
Year of Publication: 
2022
Series/Report no.: 
Research Paper No. 165
Publisher: 
South Centre, Geneva
Abstract: 
The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This paper uses open-source data to provide tentative estimates of the impact of Pillars One and Two. The methodology has been detailed so that administrators can replicate it for comparison. Further, the paper provides an assessment from the perspective of developing countries of some of the key design elements of the proposals so as to understand whether they are administrable and to foresee possible challenges.
Subjects: 
Amount A
Automated Digital Services (ADS)
Base Erosion and Profit Shifting Project (BEPS)
Digital Service Taxes (DSTs)
Double Taxation
Global Anti-Base Erosion (GloBE) Rules
Global Minimum Tax Rate
Global Tax
Global Taxation
Group of 20 (G-20)
Group of Twenty-Four (G-24)
Inclusive Framework
International Tax
International Tax Cooperation
International Taxation
Investment
Multilateral Instrument (MLI)
Multinational Enterprises (MNEs)
Organisation for Economic Co-operation and Development (OECD)
Pillar One
Pillar Two
Tax
Tax Certainty
Tax Cooperation
Tax Dispute Resolution Mechanism
Tax Law
Tax Policy
Tax Reform
Taxation
Taxing Rights
The Multilateral Convention (MLC)
Two Pillar Solution
Document Type: 
Research Report
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