Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations … are mainly hosts to MNEs. We analyse the restrictions on source taxation of services in tax treaties, particularly those … taxation of services, breaking with the residence-source dichotomy, and adopting formulary apportionment. This could be based …

research demonstrates that the comparative revenue effects of the Amount A and Article 12B taxation regimes largely depend on … Amount A or Article 12B taxation, and (c) what relief from double taxation, if any, the country will grant to domestic … taxpayers subject to taxation under either the Amount A or Article 12B regimes. …

The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The … be placed before countries for signature in early 2023. The solution ushers in a new paradigm in the taxation of …

South Centre under the Amount A and an alternative stylized DST taxation regime. Our research demonstrates that the … comparative revenue effects of the Amount A and DST taxation regimes largely depend on (a) the mix of relevant domestic economic … DST tax rate and the nature of activities to be taxed and (c) the relief from double taxation, if any, countries will …