Canada and the United States: Winners or Losers from Pillar One Amount A?

On 4 February 2021, in a panel on “Digitalisation of the Economy: OECD Blueprints Discussion” at the Canadian Tax Foundation’s virtual Transfer Pricing Conference, I spoke about possible winners and losers from the OECD’s Pillar One “Amount A” proposals. My estimates focused on tax jurisdictions grouped by GDP and region. During the session, the chair Shiraj Keshvani (PwC Canada) asked about the likely impacts of Amount A on Canada, my country of birth. This article found its own birth in my attempt to answer that question. I examine the “tax base receiving” and “tax base relieving” impacts of Amount A on high-income (HI) jurisdictions in the Americas. Since the HI Americas group is dominated the United States and Canada, finer-grained estimates of Amount A impacts are possible. My results show that the HI Americas group, and thus Canada and the United States, are likely to be losing tax jurisdictions under Amount A.