Pillar One and Pillar Two: A Confirmation of the Formulaic Apportionment and Anti-Avoidance Approaches of the Value Creation Functional DEMPE Formula Standard?

The article discusses how the value creation standard creates a “universal” definition of source as well as an anti-avoidance instrument that allows for a more mechanical and fractional manner to allocate profits. Pillar One and Pillar Two will also be scrutinized to determine if such an approach has been validated.