Transfer Pricing, Taxing Rights over Cross-Border Sales Income and the OECD Two-Pillar Response

Professor Kerrie Sadiq and Professor Rick Krever published an article ‘Transfer Pricing, Taxing Rights over Cross-Border Sales Income and the OECD Two-Pillar Response’ on the vol 4. No. 2, 2023 of the Belt and Road Initiative Tax Journal.

The article provides an overview of the operation of each of the Pillars and notes the limitations that prevent them from addressing the underlying causes of profit shifting and providing full taxing rights to sales destination jurisdictions.

Here’s the live link of the article here. All comments and suggestions are welcome!