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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

Michael Lennard

UNCTAD Transnational Corporations Journal

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.

Date: 2018
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Persistent link: https://EconPapers.repec.org/RePEc:unc:tncjou:21

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