Developing Countries should adopt Article 12B of the UN Model as their own Pillar

It is often said that one should build a house on one's own pillars. In order to adopt a treaty based solution to tax the digital economy, so far as developing countries are concerned, Amount A under Pillar One is not meant for them. Hence, developing countries need to look upto Article 12B of the UN Model and adopt it as their own pillar. This is exactly what I posited during the two-day conference jointly organised in Geneva on 27-28 November '23 by the South Centre, Geneva and Global Alliance for Tax Justice. Listen to my views in the attached video.