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Author: Joachim Englisch
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
The Inclusive Framework of the OECD/G20 currently discusses the internationally coordinated introduction of effective minimum taxes on multinational firm profits. This so-called GLOBE (global anti-base erosion) proposal is inspired by the GILTI and BEAT regimes of the 2017 US tax reform. It calls for the implementation of both income inclusion rules that would resemble very broad CFC regimes and switch-over clauses, and deduction barriers or withholding taxes for undertaxed payments in the source country. In this article, the authors make three distinct contributions. First, the authors discuss the policy rationale for the minimum tax, its advantages and potential problems. Second, the authors analyse important features of tax design, i.e. the technical dimension of the tax. Third, the authors examine the proposal in the legal and economic context of the complementary proposals that are currently under discussion (the "Pillar 1" proposals for a reallocation of taxing rights) and its compatibility with tax treaty law and EU treaty law.Full-text Paper.
Author: Joachim Englisch
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
The Inclusive Framework of the OECD/G20 currently discusses the internationally coordinated introduction of effective minimum taxes on multinational firm profits. This so-called GLOBE (global anti-base erosion) proposal is inspired by the GILTI and BEAT regimes of the 2017 US tax reform. It calls for the implementation of both income inclusion rules that would resemble very broad CFC regimes and switch-over clauses, and deduction barriers or withholding taxes for undertaxed payments in the source country. In this article, the authors make three distinct contributions. First, the authors discuss the policy rationale for the minimum tax, its advantages and potential problems. Second, the authors analyse important features of tax design, i.e. the technical dimension of the tax. Third, the authors examine the proposal in the legal and economic context of the complementary proposals that are currently under discussion (the "Pillar 1" proposals for a reallocation of taxing rights) and its compatibility with tax treaty law and EU treaty law.Full-text Paper.
Author: J. Englisch
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
The Inclusive Framework of the OECD/G20 currently discusses the internationally coordinated introduction of effective minimum taxes on multinational firm profits. This so-called GLOBE (global anti-base erosion) proposal is inspired by the GILTI and BEAT regimes of the 2017 US tax reform. It calls for the implementation of both income inclusion rules that would resemble very broad CFC regimes and switch-over clauses, and deduction barriers or withholding taxes for undertaxed payments in the source country. In this article, the authors make three distinct contributions. First, the authors discuss the policy rationale for the minimum tax, its advantages and potential problems. Second, the authors analyse important features of tax design, i.e. the technical dimension of the tax. Third, the authors examine the proposal in the legal and economic context of the complementary proposals that are currently under discussion (the "Pillar 1" proposals for a reallocation of taxing rights) and its compatibility with tax treaty law and EU treaty law.
Author:
Publisher:
ISBN: 9789087226749
Category :
Languages : en
Pages :
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Book Description
Author: Magdalena Schwarz
Publisher:
ISBN: 9783756004003
Category :
Languages : en
Pages : 0
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Book Description
Pillar Two of the OECD's two-pillar-approach to solve the tax challenges arising from digitalization provides for the introduction of global minimum taxation of large multinational entities. This is the largest project to date to reform and align international taxation. This thesis explains and analyzes the proposed rules (based on the Blueprint published in October 2020) aimed at achieving global minimum taxation. The aim of the work is also to evaluate the effectiveness of this so-called GloBE proposal and to identify possible weaknesses and potential for improvement of these rules.
Author: Schwarz
Publisher:
ISBN: 9783748936527
Category :
Languages : en
Pages : 0
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Book Description
Author: L. Eden
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global minimum tax proposal, discusses its benefits and costs, and provides policy recommendations.
Author: Valentin Bendlinger
Publisher: Kluwer Law International B.V.
ISBN: 9403532971
Category : Law
Languages : en
Pages : 449
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Book Description
Rarely in the history of international tax law have there been so many evolutions in such a short space of time: In a dizzying array of reports, work programmes, consultations and announcements, the OECD, with the active support of the EU, has created a framework for a global minimum tax (Pillar Two or GloBE). In the meanwhile, jurisdictions are faced with the practical difficulties of incorporating an incredibly complex set of rules into their domestic legal systems. This book aims to shed light on the fundamental and technical issues surrounding the global minimum tax. It seeks to unravel the complex ramifications of GloBE’s technical framework and aims to explore the relationship between the OECD’s soft law materials, including the OECD’s GloBE Model Rules and the GloBE Commentary, tax treaties and the EU’s recently adopted GloBE-Directive. The author not only analyses Pillar Two from a technical and a policy perspective but also provides for a comprehensive examination of the compatibility of Pillar Two with tax treaties and EU law. To this end, the analysis also includes practical examples and illustrates solutions to numerous technical and policy issues of Pillar Two. Among the seminal matters covered are the following: History and Background of the global minimum tax discussion. Detailed technical considerations on the design of Pillar Two, including its scope, the determination of both the ‘GloBE Income’ as well as the ‘Adjusted Covered Taxes’ and the computation of the effective tax rate as well as the computation and collection of the final ‘Top-up Tax’ liability, including the application of the QDMTT, IIR, and UTPR. Tax policy implications and deficiencies of the final design of Pillar Two. The relation of Pillar Two to the current distribution of taxing rights under bilateral tax treaties. The analysis includes the compatibility of the QDMTT, IIR, and UTPR with existing tax treaties and the resolution of potential normative conflicts, both between tax treaties and domestic implementations of Pillar Two as well as between tax treaties concluded by EU Member States and the EU’s GloBE-Directive. The role of the GloBE-Directive within the EU’s legal order, including the issue of EU internal and external competence as well as the substantive compatibility of Pillar Two with primary law, such as the fundamental freedoms. Detailed comparisons between the OECD’s GloBE Model Rules and the EU’s GloBE-Directive elucidate common points and deviations. In addition to comprehensive technical considerations, the book also provides a comprehensive tax policy perspective on the global minimum tax. For its unparalleled clarification of the issues alone, this book will prove invaluable to practitioners, tax authorities, policymakers, and academics concerned with the implementation and application of Pillar Two. ‘Valentin Bendlinger’s book is an outstandingly remarkable work on a highly complex topic. The structure, clarity of thinking, and legal argumentation are excellent, and the legal and policy results throughout are profoundly argued. The book successfully ties together broad concepts of international and European (tax) law with highly complex and novel issues of the taxation of multinational enterprises. It should be highlighted that Valentin Bendlinger succeeded in leading the reader from the history and policy through a “jungle” of unprecedented rules to overarching fundamental issues of how the new taxation framework is to be placed in the international and European legal order.’ – Prof. DDr Georg Kofler, LLM (NYU), Vienna University of Economics and Business.
Author: Mr. Shafik Hebous
Publisher: International Monetary Fund
ISBN:
Category : Business & Economics
Languages : en
Pages : 26
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Book Description
Pillar Two rules of the Inclusive Framework agreement on a minimum corporate tax (known as ‘Global Anti-Base Erosion Rules’, for short GloBE) have important implications for the design of the corporate income tax. This chapter discusses these implications particularly from the perspective of low-tax jurisdictions. It argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. Importantly, if no profit tax already exists, countries need to consider whether to adopt one, and if yes, in what form. There is a case for introducing a general profit tax beyond the GloBE rules, together with a qualifying GloBE domestic minimum top-up tax as a backstop. The familiar alternatives of efficient economic rent tax designs, however, are no longer equivalent under the GloBE. In practice, given the specifics of the rules, an efficient rent tax on in-scope multinationals cannot be combined with a statutory tax rate below a certain cutoff, because the minimum tax becomes always binding. Under the GloBE, immediate expensing particularly maintains the time-value of fully deducting the cost of investment, without impacting the GloBE effective tax rate.
Author: Werner Haslehner
Publisher: Edward Elgar Publishing
ISBN: 1035308746
Category : Law
Languages : en
Pages : 353
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Book Description
Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.
Author: Lorraine Eden
Publisher: University of Toronto Press
ISBN: 9780802007766
Category : Business & Economics
Languages : en
Pages : 788
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Book Description
Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
