The U.S. has reportedly put forward a new proposal in order to move forward negotiations for the reallocation of taxable profits of MNE groups to market jurisdictions under the OECD's Pillar 1 Blueprint. While the focus has largely been on the taxation of large digital multinationals, such as Amazon, Facebook, and Google, the latest U.S. proposal includes a framework that would focus on reforming the allocation of profits of MNEs with an approach based on two main criteria; a revenue threshold and a profit margin threshold. This approach is meant to target only the largest MNE groups, regardless of sector,...