Dr Amy Lawton co-authors chapter of new publication on the meaning of value creation in UK domestic tax law
Fri 9 July 2021
A new book published by IBFD 'Taxation and Value Creation' includes a chapter co-authored by Amy Lawton of Edinburgh Law School and Rachael O'Connor of Leeds School of Law, on the meaning of value creation in UK domestic tax law.
Amy Lawton and Rachael O'Connor are among the book's contributors, examining whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernised international tax framework.
The suggestion to “align international taxation with value creation” first emerged in the context of the OECD BEPS Project aimed at tackling aggressive tax planning strategies resulting in base erosion and profit shifting. The concept of “value creation” was then further relied on in the broader discussion that followed about the impact of digitalisation on the global economy generally and the fair allocation of taxes between countries in this new environment. Although the idea – or the guiding principle – that profits should be taxed where economic activities occur and where value is expected to be created initially received a relatively large support, it rapidly became clear (at least to academics) that there would be no obvious answer to the question “where is value being created?” in a manner that would be relevant for (international) tax purposes, inter alia in view of the different models of value creation within corporate entities.
The book is part of the The European Association of Tax Law Professors International Tax Series (EATLP). The EATLP is composed of more than 300 members who are tax law professors from the European Union. In addition, the association now includes associate members from non-EU countries.
Taxation and Value Creation is available through the publisher's website: IBFD - Your portal for tax expertise