Paul L. Caron

Monday, March 20, 2023

Avi-Yonah: The 1923 Report And The International Tax Revolution

Reuven S. Avi-Yonah (Michigan; Google Scholar), The 1923 Report and the International Tax Revolution:

The centennial of the four economists’ Report on Double Taxation (1923) provides a good opportunity to reflect on the extent the international tax regime (ITR) that was founded on the Report has changed in the past decade. While on the surface the changes brought about by the BEPS project seem radical enough to consider them an “international tax revolution”, this article will argue that the principles developed in the Report are still influential a hundred years later.

As we reach the centennial of the Report, its continuing influence can be seen despite the radical changes in the ITR in the past decade. Specifically, the Report is congruent with Pillar One in its acceptance of formulas as a valid method of allocating income among taxing jurisdictions and in its acceptance of the right of the market jurisdiction to tax income from sales into it. The Report is congruent with Pillar Two in its insistence on full taxation of cross-border income. In this general sense, it can truly be said about the ITR that “plus ca change, plus c’est la meme chose.”

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