Managing Director Vladimir Starkov wrote a Letter to the Editor on Philip Baker's "The Need for Plan B" published in Intertax in 2023. In his brief note, Dr. Starkov supports the assessment that a "Plan B" for an alternative form of taxing the digitalized economy is needed in lieu of Amount A of Pillar One. He suggests this Plan B should focus exclusively on digital business models and operate in ways similar to a digital services tax, except this new DST should be codified in a multilateral convention (MLC) to operate uniformly. Dr. Starkov also notes this DST should be non-discriminatory and linked to taxpayers' profitability and the MLC on the DST should preserve many of the Amount A MLC features nations worked so hard to agree on, including sourcing rules, access to tax certainty and dispute resolution, and obligations to relieve double taxation.
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