Rethinking taxing rights

Abstract The debate around the allocation of taxing rights between developed and developing jurisdictions has been stuck in the same place for the past 100 years. Pillar 1 of the OECD/G20 Inclusive Framework has the merit of reopening this debate, but the compromise reached so far may turn out not to be acceptable to all stakeholders. This article reviews the consequences of failing to reach an agreement and underscores the relevance of pursuing a timely alternative under the novel prospect of an UN Framework Convention.