Managing Director Vladimir Starkov wrote a Letter to the Editor on Philip Baker's "The Need for Plan B" published in Intertax in 2023. In his brief note, Dr. Starkov supports the assessment that a "Plan B" for an alternative form of taxing the digitalized economy is needed in lieu of Amount A of Pillar One. He suggests this Plan B should focus exclusively on digital business models and operate in ways similar to a digital services tax, except this new DST should be codified in a multilateral convention (MLC) to operate uniformly. Dr. Starkov also notes this DST should be non-discriminatory and linked to taxpayers' profitability and the MLC on the DST should preserve many of the Amount A MLC features nations worked so hard to agree on, including sourcing rules, access to tax certainty and dispute resolution, and obligations to relieve double taxation.
To view the full article, click here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.