Measuring Location-Specific Rents

David Elkins
12 hours ago
1 min read

By David Elkins | Volume 9 | Issue 1

This Article examines the concept of location-specific rents (LSR) and its growing influence in international tax theory as a basis for allocating taxing rights among sovereign states. Although LSR has been praised as a fair and efficient framework for source-country taxation, critics contend that it is inherently unmeasurable and therefore impractical. This Article challenges that view by arguing that LSR can, in fact, be quantified with reasonable accuracy. In doing so, it calls for a fundamental reconsideration of key features of the current international tax system, including global minimum tax initiatives and traditional distinctions between source and residence taxation.

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