Comparing Proposals to Tax Some Profit in the Market Country

This paper compares and contrasts three specific proposals that allocate taxing rights to market countries: the OECD’s “Unified Approach” (“Pillar One”), the United Nations’ “Article 12 B”; and Devereux et al.’s “Residual Profit Allocation by Income”. It aims to identify the similarities and differences of these proposals, and their consequent strengths and weaknesses. More specifically, the paper has two objectives. First, we aim to identify strengths and weaknesses that are particular to each proposal. We distinguish between features that are inherent to each proposal (that cannot be altered without altering its fundamental nature) and those that are not inherent (that can be altered without altering its fundamental nature). This exercise lays the foundations for the second objective: to show how these proposals can be improved by drawing on the most useful features of each other, or how alternative proposals can be designed by combining these features.