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Act of creation: the OECD/G20 test of “Value Creation” as a basis for taxing rights and its relevance to developing countries

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  • Michael Lennard

Abstract

This paper examines the use of the “value creation” concept that plays a central role in current OECD/G20 and European Union taxation work as a way of determining the taxation rights of countries, especially in the increasingly digitalised economy. It examines the likelihood of a consensus on whether it is an appropriate test, particularly with a view to the interests of developing countries. It also notes the need for such countries to ensure that their “policy space” in corporate taxation that is based on the place of consumption is not unduly limited by these developments.

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  • Michael Lennard, . "Act of creation: the OECD/G20 test of “Value Creation” as a basis for taxing rights and its relevance to developing countries," UNCTAD Transnational Corporations Journal, United Nations Conference on Trade and Development.
    • Handle: RePEc:unc:tncjou:21
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    File URL: https://unctad.org/system/files/official-document/diaeia2018d5a4_en.pdf?repec
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    References listed on IDEAS

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    1. Michael P. Devereux & John Vella, 2014. "Are We Heading towards a Corporate Tax System Fit for the 21-super-st Century?," Fiscal Studies, Institute for Fiscal Studies, vol. 35, pages 449-475, December.
    2. Michael P. Devereux & John Vella, 2015. "Are We Heading towards a Corporate Tax System Fit for the 21st Century?," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(04), pages 03-07, January.
    3. Alan J. Auerbach & Michael P. Devereux & Michael Keen & John Vella, 2017. "International Tax Planning under the Destination-Based Cash Flow Tax," National Tax Journal, National Tax Association;National Tax Journal, vol. 70(4), pages 783-802, December.
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    Cited by:

    1. Andres Baez & José Castro, 2019. "Problemas de la tributación internacional en Iberoamérica," Books, Universidad Externado de Colombia, Facultad de Derecho, number 1154, htpr_v3_i.

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