The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
By Lorraine Eden
The OECD’s Pillar One Blueprint, released on Oct. 12, 2020, proposes to redistribute the taxable income of multinational enterprises (MNEs) away from jurisdictions that are home and host to MNEs to the markets where MNE products are sold. In the second article of a three-part series, Lorraine Eden examines the OECD’s Economic Impact Assessment (EIA) of the Pillar One Blueprint, outlining the complexity and data problems faced in performing the assessment. The article highlights the key roles played by Global In-Scope Destination-based Sales (component C) and Global Residual In-scope Profits (component E) in determining the reallocation impacts of Pillar One. Estimates of the gap between components C and E are used to explore the likely jurisdictional impacts of Pillar One at a more fine-grained level than in the EIA.
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