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dc.contributor.authorDurst, Michael C.
dc.date.accessioned2020-06-30T14:02:27Z
dc.date.available2020-06-30T14:02:27Z
dc.date.issued2020-06-29
dc.identifier.citationDurst, M. C. (2020) A Simplified Method for Taxing Multinationals for Developing Countries: Building on the ‘Amount B’ Proposal to Repair the Transactional Net Margin Method, ICTD Working Paper 108, Brighton, Institute of Development Studiesen
dc.identifier.isbn978-1-78118-659-6
dc.identifier.urihttps://opendocs.ids.ac.uk/opendocs/handle/20.500.12413/15482
dc.description.abstractThis paper considers whether the ‘Amount B’ proposal currently being negotiated in the Inclusive Framework, for the attribution of fixed remuneration for the ‘routine’ distribution and marketing activities of MNE affiliates, may offer a useful template for the re-working of the widely used ‘transactional net margin’ transfer pricing method (TNMM). The TNMM has for years posed severe difficulties for tax administrations around the world, especially in developing countries. The paper focuses especially on two variants of the Amount B proposal which have been offered by Johnson & Johnson and Procter & Gamble, and suggests how a revised TNMM might be expanded to apply to MNE affiliates engaged in activities in addition to marketing and distribution. The paper acknowledges that a restructured TNMM would remain in some ways an imperfect tax administration instrument, and that its construction will involve some unavoidable technical challenges (as would be true of any meaningful reform of rules for the international division of profits for tax purposes). Nevertheless, a restructured TNMM could provide significant relief to hard-pressed developing-country tax administrations, and the paper argues that it should figure among the objectives of the OECD’s current efforts at international tax reform.en
dc.language.isoenen
dc.publisherInstitute of Development Studiesen
dc.relation.ispartofseriesICTD Working Paper;108
dc.rights.urihttp://creativecommons.org/licenses/by-nc/4.0/en
dc.subjectDevelopment Policyen
dc.subjectEconomic Developmenten
dc.subjectFinanceen
dc.subjectGlobalisationen
dc.subjectGovernanceen
dc.titleA Simplified Method for Taxing Multinationals for Developing Countries: Building on the 'Amount B' Proposal to Repair the Transactional Net Margin Methoden
dc.typeSeries paper (non-IDS)en
dc.rights.holderInstitute of Development Studies 2020en
dc.identifier.teamGovernanceen
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