Still Under-Taxing the Digital MNE? Assessing the Tax Principles of Pillar One in the BEPS Project

A new principle of international taxation that gives taxing rights on the profits of digital multinational firms (MNEs) has been proposed in Pillar One of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. This note delineates this tax principle in a simple model and points out that while the new framework allows taxation of MNEs profits that could not be taxed before, it includes incentives for excessive reductions in the corporate tax rate.