| dc.description.abstract | This thesis considers the current multilateral corporate tax reform process – which has been characterised by the OECD as being in pursuit of a normative goal of aligning the allocation of the tax base with ‘value creation’ – through a value-theoretical lens. It is a ‘materialist’ analysis because the value-theoretical standpoint it develops and adopts is the classical one which places a production boundary around material production and treats movements of value outside that boundary as transfers. The thesis is divided into three parts, posing distinct but interrelated research questions, and each developing an interdisciplinary argument in both tax law and political economy. Part I demonstrates the utility of a materialist distinction between surplus and transfer by means of an analysis of case law regarding whether income falls to be treated as taxable trading profits. It proceeds to develop an original interpretation of the underlying value theory. Part II combines that value theoretical perspective with an original jurisprudence of offshore, and thereby develops a structural analysis of global contestation over revenues between capital and the state. Particular attention is drawn to the role of global value chains. Part III analyses OECD consultation documents and corporate sector responses published pursuant to the recent international corporate tax reform process. It is shown that ‘value creation’ here means either (i) labour outside the production boundary and associated with value capture, or (ii) value absorption in the sphere of consumption. It is argued that these meanings arise from the need to attribute profitability to something, given that prevailing norms prevent it from being allocated upstream in global value chains to activity within the production boundary. The reform process therefore appears to be a project to retain the global tax base in wealthy states to the extent it is not conceded to offshore. | en_US |
