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 therefore be allocated according to standards commonly considered...

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 therefore be allocated according to standards commonly considered...

This article uses the example of Google to discuss value creation within multinational platform firms and the tax challenges resulting from a disconnect between the current international corporate tax system and economic reality brought about by the digitalisation

The OECD seeks to align transfer pricing and profit taxation with value creation. This article argues that taking this objective seriously requires profit splitting. This is shown by applying Shapley value theory to the problem of allocating a firm's profit tax base to the jurisdictions in which...

This study considers advantages of relying on micro-data to assess average tax rates on labour, capital and transfer income and presents some illustrative results. The analysis emphases the importance of matching taxpayer-level information to income flows, and notes difficulties in interpreting...