Fascinating - both that ATAF is empowered to table its own proposal, following discussions with the US rather than the OECD, and also the detail: pointing towards a comprehensive apportionment of global profits of large multinationals...
Thinking more about @ATAFtax proposal, it seems highly significant. It returns to the spirit of G24 proposal which Inclusive Framework backed in early 2019 for OECD to evaluate (as 1 of 3). It was never evaluated, just discarded in favour of the secretariat's 'unified' proposal.
This new iteration creates a problem for the OECD, and for the G7 members who drive decisions there. It has become evident, again, that others are simply ignored. But the others are no longer standing quietly by...
So where does OECD land? A weak/thin/absent pillar 1, and a pillar 2 with more ambition but where (per OECD blueprint) barely any of the gains accrue to non-members?
It feels like @ATAFtax has piled on the pressure: either OECD delivers something much fairer in July (e.g. the METR), or the momentum to switch to the UN and/or explosive unilateral splintering, may be unstoppable. Watch this space!
Ps. Momentum, via @FACTIpanel and wider UN system moves, may be unstoppable anyway...

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More from @alexcobham

12 May
Results in: the court overturns EC finding of Luxembourg state aid to Amazon...
While confirming Lux state aid to Engie...
Meh.
Read 14 tweets
28 Apr
As frustrated members made clear in 2020, the OECD Inclusive Framework does not make the decisions in the corporate tax negotiations they nominally lead, and nor even is it the G20 that gave the OECD the mandate - it is (still) the G7.

So where do they stand on Biden's 21% plan?
There are two important elements to this. First, do countries support a 21% minimum corporate tax rate? And second, do they support a fair distribution of the right to tax the undertaxed profits?
Starting with the US: safe to say, Biden administration supports Biden plan. That includes the 21% minimum rate; and at least opens the door to a distribution that doesn't give first bite at revenues to the headquarters country (hence GILTI/BEAT reforms). taxjustice.net/2021/04/08/300…
Read 21 tweets
23 Apr
It is *very* difficult to understand why so much effort is being made to keep the Irish government onside in the OECD talks. If the talks deliver, the business model is bust - and the government's focus should be on finding a better future that doesn't rob others of revenues.
Ireland imposes large revenue costs on others - we estimate this one jurisdiction accounts for some 3.7% of the global losses due to tax abuse. iff.taxjustice.net/#/profile/IRL Global rankings graphic: Ireland ranks 11th on the CorporateHarm to other countries graphic: Ireland imposes $16 billion
As OECD negotiation on 'pillar 1' seem to be moving towards Biden administration's proposal that would not require global treaty change; and 'pillar 2' would be a coalition of the willing on a minimum tax rate - there'd no longer be an opportunity for Ireland or others to block.
Read 4 tweets
23 Apr
This is quite something. The French government's position on the EU move to public country by country reporting for multinational companies, a key measure to curb profit shifting abuses, appears to have been captured entirely by... the business lobby.
The French government's two-pager on its negotiating position - its critical demands - has been leaked. According to the scoop in @Contexte, the metadata of the pdf reveal the hand not of diplomats or ministers, but of a senior employee of MEDEF - the French business lobby group.
This revelation gives us two things: first, we can look at the position that MEDEF has convinced the French government to take up, and see the priorities of the lobbyists; and second, we can understand a bit more the wider French government position on tax, including at the OECD.
Read 21 tweets
22 Apr
This resolves one international tax mystery, but raises another set of questions.

It turns out that *France* proposed the trivially low 12.5% rate for a global minimum corporate tax... 🧵
It has long been something of a mystery why the OECD secretariat pushed 12.5% in the 'pillar 2' discussions.

One theory went like this.
The secretariat were committed, or saw the commitment of some major member states, to keep pillars 1 and 2 together. But pillar 1 (as the secretariat proposed it) needed treaty change, meaning Ireland etc could block. So to minimise that risk, pillar 2 had to be 'acceptable'...
Read 42 tweets
4 Dec 20
History faces forwards as well as backwards. As we prepare for the second day of our #ImperialInequalities conference today, and our new @FPCThinkTank
piece is published, I've blogged on whether and how the UK could move beyond its imperial legacies
taxjustice.net/2020/12/04/the…
Registration for day 2 of #ImperialInequalities is still open, and the events get underway in just over three hours
Dr Ndongo Samba Sylla @nssylla opens day 2 of #ImperialInequalities, with a keynote on 'Colonial macroeconomics: Then and now' in which he highlights the commonality between imperial approaches and contemporary economic policies
Read 23 tweets

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