Adam H. Rosenzweig (Washington University), Stateless Public Goods, 74 Kan. L. Rev. 235 (2025):

The rise of the digital economy has proven to be one of the most significant developments in modern economic history, not only due to its explosive economic growth but also for its potential to improve the quality of life for billions of people around the world.  At the same time, the digital economy has presented one of the most significant challenges to global tax and regulatory institutions.  This dichotomy has been reflected through the experiences with two separate global initiatives: (1) the OECD Base Erosion and Profit Shifting (“BEPS”) global tax reform project and (2) the UN 2030 Sustainable Development Goals (“SDG”) global development project.  While at first glance these may appear to have little in common, what unifies them is their attempt to address the unprecedented challenges presented by the emerging global digital economy. On one hand, the BEPS project has identified the global digital economy as the single most significant opportunity to tap into new, previously uncollected sources of revenue in the world, while on the other, the SDG project has identified it as having the potential to reduce global poverty by up to half.  Unfortunately, each has faced repeated stumbling blocks which have prevented both from fully achieving their stated goals. This article will propose a novel solution to overcome these challenges by linking the revenue collection potential of the BEPS project with the global development initiatives of the SDG project through the creation of a new multinational GDPG Trust Fund. 

The GDPG Trust Fund would leverage the best aspects of both projects, overcome the obstacles confronting them, and ultimately fulfill their promise to improve both the world’s global economic institutions and the quality of life for millions of people around the world.

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