The October 2020 Pillar One proposal by the OECD/Inclusive Framework (IF) is designed to shift some portion of the global pre-tax profits of multinational enterprises (MNEs) in automated digital services (ADS) and consumer-facing businesses (CFB) to Market jurisdictions where ADS and CFB...

The emergence of GVCs and recently superstar firms has been well documented, but less attention has been paid to what these joint developments mean for how we think about and need to examine FDI. Against this setting, I explore four dimensions of FDI: its conceptual aspects, measurement,...

This study investigates changes in the number and the size distribution of firms in Sweden in the period 1968-1993. The number and the size distribution of Swedish firms are compared to the number and the size distribution of firms in eleven European countries. A decrease in the number of...

Tax Management International Journal, 50.2 (Feb. 2021): 90-97. Reproduced with permission from Bloomberg Tax (Feb 5, 2021). Copyright 2021 The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com.Abstract: The Amount B proposal in the Pillar One Blueprint released by...

A key motivation underlying the October 2020 OECD Pillar One and Pillar Two Blueprints is the goal of reducing tax complexity for taxpayers and tax authorities. In this article, we assess the tax complexity of the Blueprints relative to the 2017 OECD Transfer Pricing Guidelines (TPG) and the...

On 4 February 2021, in a panel on “Digitalisation of the Economy: OECD Blueprints Discussion” at the Canadian Tax Foundation’s virtual Transfer Pricing Conference, I spoke about possible winners and losers from the OECD’s Pillar One “Amount A” proposals. My estimates focused on tax...

The OECD’s Pillar One Blueprint proposes a new taxing right, Amount A, that would shift the pre-tax profits of multinational enterprises (MNEs) from Residence and Source jurisdictions to Market jurisdictions. The Amount A formula provides multiple opportunities for both MNEs and tax...

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...

The third round of proposals for taxing the digital economy (the Pillar One and Pillar Two Blueprints) were released in mid-October 2020 together with an Economic Impact Assessment of the proposed changes. The Blueprints and Economic Impact Assessment involve several “leaps of faith into the...

In this study, we have analysed the role of the largest companies in the Finnish economy. According to the results, the list of ten largest companies in terms of their domestic value added is diverse and includes companies operating in the manufacturing industry, the service industry, as well as...