TY  - JOUR
AU  - Kostić, Svetislav
AU  - Navarro, Aitor
PY  - 2023
UR  - https://ralf.ius.bg.ac.rs/handle/123456789/1394
AB  - Mobility should be at the core of the reallocation of taxing rights debate. With such a premise in mind, this contribution addresses this issue within Pillar One in its two components: the apportionment of taxing rights to market jurisdictions on residual profits of the most significant MNEs worldwide (Amount A) and the standardization of the remuneration of related party distributors that perform baseline marketing and distribution activities in market jurisdictions (Amount B). The aim is to show that not only the mobility of individuals but also that of MNE structures when deciding on their presence in market jurisdictions are relevant in building new paradigms on the allocation of taxing rights at a cross-border level through the specific impact of the said OECD proposal. Even if Pillar One seems doomed to fail, lessons learned from its design and its specific impact on mobility matters should inform further developments in reshaping international taxation.
PB  - Kluwer Law Int, Alphen Aan Den Rijn
T2  - Intertax
T1  - Pillar One and Mobility - A Truly Global Solution?
EP  - 850
IS  - 12
SP  - 840
VL  - 51
UR  - conv_3286
ER  - 

@article{
author = "Kostić, Svetislav and Navarro, Aitor",
year = "2023",
abstract = "Mobility should be at the core of the reallocation of taxing rights debate. With such a premise in mind, this contribution addresses this issue within Pillar One in its two components: the apportionment of taxing rights to market jurisdictions on residual profits of the most significant MNEs worldwide (Amount A) and the standardization of the remuneration of related party distributors that perform baseline marketing and distribution activities in market jurisdictions (Amount B). The aim is to show that not only the mobility of individuals but also that of MNE structures when deciding on their presence in market jurisdictions are relevant in building new paradigms on the allocation of taxing rights at a cross-border level through the specific impact of the said OECD proposal. Even if Pillar One seems doomed to fail, lessons learned from its design and its specific impact on mobility matters should inform further developments in reshaping international taxation.",
publisher = "Kluwer Law Int, Alphen Aan Den Rijn",
journal = "Intertax",
title = "Pillar One and Mobility - A Truly Global Solution?",
pages = "850-840",
number = "12",
volume = "51",
url = "conv_3286"
}

Kostić, S.,& Navarro, A.. (2023). Pillar One and Mobility - A Truly Global Solution?. in Intertax
Kluwer Law Int, Alphen Aan Den Rijn., 51(12), 840-850.
conv_3286

Kostić S, Navarro A. Pillar One and Mobility - A Truly Global Solution?. in Intertax. 2023;51(12):840-850.
conv_3286 .

Kostić, Svetislav, Navarro, Aitor, "Pillar One and Mobility - A Truly Global Solution?" in Intertax, 51, no. 12 (2023):840-850,
conv_3286 .