Reallocation of Residual Profits under OECD Pillar One: Myths and Realities

The Amount A OECD Pillar One proposal aims to expand taxing rights in market jurisdictions by reallocating profits of large, highly profitable MNEs based on destination sales, regardless of physical presence. The viability of this proposal is currently under question following the announced distancing from the “Global Tax Deal” by the current US Administration. Nonetheless, from a policy viewpoint, this crisis turning point arguably offers the opportunity to more carefully assess what would be the distributional effects of the initiative from the point of view of developing countries and to explore potential alternatives in light of the currently perceived stalemate. This study is in particular concerned with an empirical assessment of such distributional effects, addressing the matter within the broader context of the structural shortcomings of the current international business taxation regime. In doing so, this study points out to various design and implementation issues associated with the proposal and envisages possible alternative solutions.