1 PRELIMINARY DRAFT October 2019 Global inequalities in taxing rights: An early evaluation of the OECD tax reform proposals Alex Cobham (Tax Justice Network) 1 Tommaso Faccio (University of Nottingham) Valpy FitzGerald (University of Oxford) Abstract. The current OECD process to reform the international rules governing corporate tax, aimed to achieve a consensus solution by 2020, has finally recognised the need to introduce elements of formulary apportionment to allocate the profits of multinationals and is framed explicitly in terms of redistributing taxing rights between countries. In this paper we provide the first public evaluation of the redistribution of taxing rights associated with the leading proposals of the OECD, IMF and the Independent Commission for the Reform of International Corporate Taxation (ICRICT). The first key finding is that that reallocation of taxing rights towards “market jurisdictions”, as it is currently understood, is likely to be of little benefit to non-OECD countries. Indeed, the proposal is likely to reduce revenues for a range of lower-income countries. Second, all of the proposals deliver a much broader distribution of benefits if some element of taxing rights is apportioned according to the location of multinationals’ employment, and not only of sales. 1 Alex Cobham: alex@taxjustice.net; Tommaso Faccio: tommaso.faccio@nottingham.ac.uk; Valpy Fitzgerald: edmund.fitzgerald@qeh.ox.ac.uk. Alex Cobham is chief executive of the Tax Justice Network; Tommaso Faccio is Head of Secretariat of ICRICT; and Valpy Fitzgerald is professor emeritus of international development finance at the University of Oxford, and an ICRICT Commissioner. We are grateful to Javier Garcia-Bernardo for excellent research assistance.