The debate on the allocation of multinational enterprises’ profits from a legal, tax principles, political and policy perspective

This doctoral thesis explores how multinational enterprises’ profits are allocated among jurisdictions under international tax rules. It takes a theoretical approach, assessing core normative questions: what principles should guide the profit allocation, and how can they align with the realities of tax policy and politics. It compares the arm’s length principle with alternatives like the OECD’s Amount A, showing a potential shift in principles. The work highlights political constraints, the lack of universally shared principles, and the need for a more coherent framework for global tax governance. This thesis seeks to provide a foundation for future reforms of the international tax regime.