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Bulletin for International Taxation, 2021 (Volume 75), No. 5


In this article, the authors make a case for repurposing the OECD Pillar One from a mechanism for reallocating taxing rights to a global tax on the largest and most profitable MNEs’ market-based profits. Such global tax would have the hybrid features of a net-basis corporate income tax and a turnover-basis digital services tax through a conversion formula that ensures a low-rate DST on sales can replicate a higher rate CIT on a country’s share of the profit determined using under the formulary allocation method. More importantly, the authors instill a common purpose of the international tax consensus – to help finance spending on achieving the UN Sustainable Development Goals and targets committed in the Paris Agreement. They also argue that the repurposed Pillar One would be a win, win, win proposition for governments, MNEs and the Planet.