The OECD seeks to align transfer pricing and profit taxation with value creation but fails to provide a clear … definition. This paper argues that value creation requires international cooperation and that the profit tax base should … claim that current rules of international profit taxation are aligned with value creation is rejected. If anything, the OECD …

international tax regime in which the right of taxing the profit earned on the direct sales of digital services is split between the …

). One of two reform pillars aims at granting market countries the right to tax supernormal ("residual") profit without … against the OECD proposal to use a sales-based formula for allocating an MNE's group profit. Simply splitting each market … country's residual profit contribution by an MNE-independent key is to be preferred. …

The adequate pricing of intellectual property (“IP”) for tax reporting is a largely unsettled issue. Transactional … profit-based methods are on the rise although only rated as “methods of last resort” by the OECD. This paper focuses on … regulated profit splitting and compares this transfer pricing rule with one allowing multinationals to price IP freely subject …