A word from Professor Scott Wilkie:
Professor Jinyan Li and Ms. Sophie Chatel, both drawing on their expertise and experience in international tax, have recently co-written this article published by the International Bureau of Fiscal Documentation in the Bulletin for International Taxation, which is now freely available and can be accessed by clicking here.
They reimagine and propose to repurpose the continuing OECD Pillar One proposal by proposing their own approach to a global and multilateral regime to tax corporate profits. The international conversation on a range of subjects converging on whether there is indeed or should be something in the nature of a “global tax system” rather than more typical and historical approaches to reconciling intersecting tax claims, using transfer pricing direction in Article 9 of the OECD Model Tax Convention and related transfer pricing guidance refashioned and amplified with the initial results of the OECD’s Base Erosion and Profit Shifting project is a complex and multifaceted conversation. Many views have been expressed, made even more immediate by the United State’s Presidential “Made In America Tax Plan” unveiled recently. Professor Li’s and Ms Chatel’s views will be a welcome addition to that conversation.
Repurposing Pillar One into an Incremental Global Tax for Sustainability: A Collective Response to a Global Crisis can be accessed by clicking the link.