Niels Johannesen (Oxford)
John Vella (Oxford)
Michelle Hanlon (MIT)
Jim Hines (Michigan)
Wolfgang Schön (Max Planck)
Lilian Faulhaber (Georgetown)
What is OMG?
On behalf of the Oxford University Centre for Business Taxation, University of Michigan, Massachusetts Institute of Technology, Max Planck Institute for Tax Law and Public Finance, and Georgetown University Law Center, we are excited to announce a seminar on Monday 17 June, 2024, at 5.00pm UK time, 6.00 pm Central European time and 12.00 New York time.
This speaker series - which began in 2021 - is interdisciplinary, with experts in taxation from law, economics, and accounting presenting their work. OMG is hosted on Zoom and is free to attend.
Abstract
This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative analysis of the proposals using an integrated economic and legal approach. Our assessment is based on the two proposals’ ability to generate tax revenue and their implications for net-importing countries. Our legal analysis demonstrates significant differences between the two proposals in the implied reallocation of taxing rights, depending on the considered (digital) business model. Interestingly, we find that overall and despite its complexity, Pillar I Amount A addresses the specific interests of developing countries better than Art. 12B UN Model. In particular, Pillar I Amount A will likely outperform the UN’s proposal in terms of its tax revenue potential.
