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Monday, March 20, 2023
Avi-Yonah: The 1923 Report And The Worldwide Tax Revolution
Reuven S. Avi-Yonah (Michigan; Google Scholar), The 1923 Report and the Worldwide Tax Revolution:
The centennial of the 4 economists’ Report on Double Taxation (1923) offers a superb alternative to mirror on the extent the worldwide tax regime (ITR) that was based on the Report has modified up to now decade. Whereas on the floor the modifications led to by the BEPS challenge appear radical sufficient to think about them an “worldwide tax revolution”, this text will argue that the ideas developed within the Report are nonetheless influential 100 years later.
Conclusion
As we attain the centennial of the Report, its persevering with affect might be seen regardless of the unconventional modifications within the ITR up to now decade. Particularly, the Report is congruent with Pillar One in its acceptance of formulation as a sound technique of allocating earnings amongst taxing jurisdictions and in its acceptance of the appropriate of the market jurisdiction to tax earnings from gross sales into it. The Report is congruent with Pillar Two in its insistence on full taxation of cross-border earnings. On this basic sense, it could really be mentioned concerning the ITR that “plus ca change, plus c’est la meme selected.”
https://taxprof.typepad.com/taxprof_blog/2023/03/avi-yonah-the-1923-report-and-the-international-tax-revolution.html
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