Abstract
After a century of convergence and consolidation, the international tax regime is at a crossroads. A recent program promoted by the OECD, known as the two pillars program, departs in many ways from long standing norms of the regime. But the OECD and many states insist that the foundations of the regime have not changed, portraying the two pillars as a negotiated, pragmatic compromise that responds mainly to the challenges that the digital economy presented to the old rules. This article rejects this portrayal, arguing that the program is far from being a balanced or a truly negotiated compromise between developed and developing states, and that the program introduces innovations, perhaps long needed innovations in the views of some, but still innovations that are difficult to reconcile, as a matter of principle, with the foundational tenets of the international tax regime.
Recommended Citation
Brauner, Yariv
()
"The Foundations of International Taxation: Knocked from Post to Pillars,"
Akron Law Review: Vol. 58:
Iss.
1, Article 2.
Available at:
https://ideaexchange.uakron.edu/akronlawreview/vol58/iss1/2