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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...
Persistent link: https://www.econbiz.de/10013242330
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...
Persistent link: https://www.econbiz.de/10013242793
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...
Persistent link: https://www.econbiz.de/10013248926
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...
Persistent link: https://www.econbiz.de/10013248927
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...
Persistent link: https://www.econbiz.de/10013248928
compliance lens. In so doing, it highlights the importance that third parties to the taxpayer-government relationship act at arm … also draws on the tax compliance perspective to make some preliminary observations about valuation methodologies …
Persistent link: https://www.econbiz.de/10013251380
norms are relevant, the enforcement elasticity of government interventions may be indeterminate. Finally, I suggest that … self-inspections can be usefully classified in a scheme that sort enforcement strategies in terms of whether government …(ii), where intervention in compliance is necessarily ex post, social norms play a critical role …
Persistent link: https://www.econbiz.de/10013252230
upon this uncertainty in their reporting practices, such that tax compliance lags and the IRS has a difficult time … greater tax compliance. Put somewhat differently, in the Information Era in which we exist, it is simply no longer true that …
Persistent link: https://www.econbiz.de/10013290580
This Essay proposes a conceptual framework for the regulation of transactions involving cryptocurrencies. Cryptocurrencies offer tremendous opportunities for innovation and development but are also uniquely suited to facilitate illicit behavior. The regulatory framework suggested herein is...
Persistent link: https://www.econbiz.de/10013032191
the government to employ. There is, however, another potential means by which the government can improve tax compliance …
Persistent link: https://www.econbiz.de/10013032515