Winners and Losers : the OECD's Economic Impact Assessment of Pillar One

The OECD’s Pillar One Blueprint, released on 12 October 2020, proposes to redistribute the taxable income of multinational enterprises (MNEs) away from jurisdictions that are home and host to MNEs to the markets where MNE products are sold. This article examines the OECD’s Economic Impact Assessment (EIA) of the Pillar One Blueprint, outlining the complexity and data problems faced in performing the assessment. The article highlights the key roles played by Global In-Scope Destination-based Sales (component C) and Global Residual In-scope Profits (component E) in determining the reallocation impacts of Pillar One. Estimates of the gap between components C and E are used to explore the likely jurisdictional impacts of Pillar One at a more fine-grained level than in the EIA