IDEAS home Printed from https://ideas.repec.org/a/kap/itaxpf/v32y2025i3d10.1007_s10797-024-09859-4.html
   My bibliography  Save this article

Tax revenue from Pillar One Amount A: country-by-country estimates

Author

Listed:
  • Mona Barake

    (Paris School of Economics
    Skatteforsk Center for Tax Research, Norwegian University of Life Sciences (NMBU))

  • Elvin Pouhaër

    (Paris School of Economics)

Abstract

This paper presents first-round simulations of the tax revenues arising from the Pillar One Amount A proposal of the G20/OECD inclusive framework on base erosion and profit shifting for 2016–2025. Amount A aims at revising taxing rights on multinational enterprises with at least €20 billion in revenue and profitability above 10%. We consider the latest available Pillar One Amount A rules as detailed in the “Multilateral Convention to Implement Amount A of Pillar One” (OECD 2023b). In a first step, we identify the multinationals that would be “covered” under Pillar One Amount A. Then, by combining micro and macro data sources, we create a database that approximates these Covered Groups’ worldwide distribution of destination-based revenues, profits, employees, and tangible assets. Destination-based revenues serve to reallocate Amount A profits across jurisdictions. Finally, we account for double taxation relief to obtain country-level net revenue estimates from Pillar One Amount A. The aggregate additional tax revenue arising from Pillar One Amount A varies from €5.7 billion in 2020 to €10.9 billion in 2022. We provide country-specific estimate ranges and a comparison to digital taxes. The trade-off between Amount A and digital taxes is unclear and may vary from one country to another. Testing for the implications of various provisions of Amount A rules, we observe that the extent of taxing rights redistribution is seriously affected by the Marketing and Distribution Safe Harbour (MDSH), while the profit reallocated to low and lower-middle-income jurisdictions crucially depends on the tail-end revenues provision.

Suggested Citation

  • Mona Barake & Elvin Pouhaër, 2025. "Tax revenue from Pillar One Amount A: country-by-country estimates," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 32(3), pages 680-740, June.
  • Handle: RePEc:kap:itaxpf:v:32:y:2025:i:3:d:10.1007_s10797-024-09859-4
    DOI: 10.1007/s10797-024-09859-4
    as

    Download full text from publisher

    File URL: http://link.springer.com/10.1007/s10797-024-09859-4
    File Function: Abstract
    Download Restriction: Access to full text is restricted to subscribers.

    File URL: https://libkey.io/10.1007/s10797-024-09859-4?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    As the access to this document is restricted, you may want to search for a different version of it.

    More about this item

    Keywords

    Pillar One Amount A; Two-pillar solution; International taxation;
    All these keywords.

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • F55 - International Economics - - International Relations, National Security, and International Political Economy - - - International Institutional Arrangements
    • H27 - Public Economics - - Taxation, Subsidies, and Revenue - - - Other Sources of Revenue
    • H73 - Public Economics - - State and Local Government; Intergovernmental Relations - - - Interjurisdictional Differentials and Their Effects

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:kap:itaxpf:v:32:y:2025:i:3:d:10.1007_s10797-024-09859-4. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Sonal Shukla or Springer Nature Abstracting and Indexing (email available below). General contact details of provider: http://www.springer.com .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.