Biography
Samuel is working on the research project “Towards Market-Based Taxation: A Framework for Developing Countries to Address the Tax Challenges Exacerbated by the Digitalisation of the Economy”. This project examines the structural weaknesses of the current international tax regime, which has historically limited the ability of market jurisdictions to tax profits earned by foreign enterprises operating within their borders. The project sheds light on how traditional concepts such as permanent establishment, the ability-to-pay principle, and value creation defined largely by supply-side contributions are increasingly becoming ineffective yardsticks for allocating taxing rights in an era where businesses can (and do) generate huge profits from a country even without physical footprints therein, and where user participation and market engagement are central and indispensable to value creation for most businesses. By adopting a normative approach, the project aims to develop a sustainable framework that allocates a fair share of taxing rights to market jurisdictions, and propose a solution to help address the broader inequalities embedded in the international tax system.
