Slicing the Shadow: OECD Consultation Highlights Profit Allocation Difficulties

    View Author March 2019
    The Organisation for Economic Cooperation and Development (OECD) convened international tax specialists in Paris earlier this March to discuss public submissions in response to proposals for, among other things, revised profit allocation and nexus rules. Jeff VanderWolk, Tax Strategy & Benefits partner, who was in attendance, observes in this Bloomberg Tax article that the allocation of profits among taxing jurisdictions – once described by the Supreme Court as like “slicing a shadow” – is unlikely to be the subject of agreement by the 129 member countries of the Inclusive Framework, who have not yet even defined the problem they are seeking to solve.