Case Study Analysis of the OECD Pillar One and Pillar Two Allocations to Developing Countries – What Has Changed Since the 2020 Blueprints?

This article reviews the changes to the OECD’s Pillar One and Pillar Two solutions since the 2020 Blueprints by updating the case-study approach simulating the operation of the proposals under three profit-shifting schemes. The analysis reveals significant changes to Pillar One and Two integration and further increases tax revenue unpredictability.