Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/290402 
Year of Publication: 
2024
Series/Report no.: 
ZEW Discussion Papers No. 24-022
Publisher: 
ZEW - Leibniz-Zentrum für Europäische Wirtschaftsforschung, Mannheim
Abstract: 
This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative analysis of the proposals using an integrated economic and legal approach. Our assessment is based on the two proposals' ability to generate tax revenue and their implications for net-importing countries. Our legal analysis demonstrates significant differences between the two proposals in the implied reallocation of taxing rights, depending on the considered (digital) business model. Interestingly, we find that overall and despite its complexity, Pillar I Amount A addresses the specific interests of developing countries better than Art. 12B UN Model. In particular, Pillar I Amount A will likely outperform the UN's proposal in terms of its tax revenue potential.
Subjects: 
Digital Economy
Corporate Tax
Global Tax Reform
OECD Pillar 1
Developing Countries
JEL: 
F23
H25
H32
K34
Document Type: 
Working Paper

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