The multilateral solutions for the taxation of the digital economy: From thefailure of Pillar One`s Amount A to the doubts on article 12B of the UN ModelTax Convention

Abstract

Taxation of the profits derived by digitalized  multinational enterprises is one of the most important  challenges of the international tax system. Currently, many  jurisdictions have  implemented unilateral  measures while multilateral solutions are still under  negotiation at different  international organizations.  However, it is apparent that  the solution proposed by  the OECD and the G-20 will  not reach enough support.  Therefore, other multilateral solutions should be  explored. In this paper, both  Amount A of Pillar  One proposed by the OECD  and the G-20 and a  multilateral solution based  on article 12B of the UN  Model Tax Convention are  analyzed as well as their  eventual results in order to  check if these solutions are  suitable to provide a  homogeneous solution to  the challenges of digital  economy.

This work has been carried out within the framework of the research project "The new international standards of fair taxation and their implementation in the Spanish tax system (PID2021-123427NB-I00)", funded by the Ministry of Science and Innovation