Tuesday, February 11, 2020
Assaf Harpaz (SJD 2020, Duke), The OECD Unified Approach: Nexus, Scope, and Coexisting With DSTs, 96 Tax Notes Int'l 909 (Dec. 9, 2019):
This article comments on the OECD Secretariat Proposal for a “Unified Approach” under Pillar One, released October 9, 2019. The article focuses on the proposal’s scope, nexus, administration and compliance, proposed “Amount C” and compatibility with unilateral digital service taxes. The article suggests a nexus that does not consider size-limiting worldwide revenue thresholds and offers an alternative de minimis country-specific sale-based proposal. Comments on the OECD proposal were submitted by the author as part of the OECD’s public consultation process in November 2019.