Aligning the Location of Taxation with the Location of Value Creation: Are We There Yet!?!

Abstract

In this 75th anniversary issue of the Bulletin for International Taxation, Angelo Nikolakakis examines critically the implications of the initiatives – the OECD/G20 Base Erosion and Profit Shifting Project and the (resulting) Pillars One and Two – that have been suggested as ways of reforming the international tax regime. The analysis is focussed in particular on the implications of these initiatives with regard to the goal of aligning the location of taxation with the location of value creation.