Exploitation, international taxation, and global justice

I investigate the central principle that underlies the OECDs tax base erosion and profit shifting initiative. The principle claims that (corporate) profits should be taxed where economic activities deriving the profits are performed and where value is created. First, I argue that its plausibility depends on establishing that states have an entitlement to the productive factors in their territory, and therefore to a share of the value created by employing those factors. Second, I maintain that this cannot presently be established. If states fail to discharge duties requiring wealth redistribution, they do not have an unqualified right to the productive factors in their territory. Even if they are not subject to such duties, states can only legitimately claim a share in the fair value of the goods created. I show that given widespread exploitation in global value chains, the market prices of (intermediary) goods do not reflect their fair value.