Taxing Multinationals : the GloBE Proposal for a Global Minimum Tax

Taxing Multinationals : the GloBE Proposal for a Global Minimum Tax PDF 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.

Taxing Multinationals : the GloBE Proposal for a Global Minimum Tax

Taxing Multinationals : the GloBE Proposal for a Global Minimum Tax PDF 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.

International Effective Minimum Taxation - the GLOBE Proposal

International Effective Minimum Taxation - the GLOBE Proposal PDF 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.

International Effective Minimum Taxation - The GLOBE Proposal

International Effective Minimum Taxation - The GLOBE Proposal PDF 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.

Taxing Multinationals

Taxing Multinationals PDF 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.

Potential Repsonse to GLOBE : Domestic Minimum Taxes in Countries Affected by the Global Minimum Tax

Potential Repsonse to GLOBE : Domestic Minimum Taxes in Countries Affected by the Global Minimum Tax PDF Author: N. Noked
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
In this article, the author examines the OECD's global anti-base-erosion (GLOBE) proposal and recommends that countries consider adopting a domestic minimum tax that would apply to the income that would otherwise be taxed under GLOBE. He argues that a domestic minimum tax modeled after GLOBE would not materially affect the overall tax liability of multinationals or create additional complexity, and it would help countries whose primary taxing rights might be eroded by GLOBE.

The OECD GloBE Proposal - a Decisive Step Towards Uniform Global Minimum Taxation?

The OECD GloBE Proposal - a Decisive Step Towards Uniform Global Minimum Taxation? PDF 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.

The OECD GloBE proposal – a decisive step towards uniform global minimum taxation?

The OECD GloBE proposal – a decisive step towards uniform global minimum taxation? PDF Author: Schwarz
Publisher:
ISBN: 9783748936527
Category :
Languages : en
Pages : 0

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Book Description


The 'Pillar Two' Global Minimum Tax

The 'Pillar Two' Global Minimum Tax PDF 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.

A Guide for Developing Countries on How to Understand and Adapt to the Global Minimum Tax

A Guide for Developing Countries on How to Understand and Adapt to the Global Minimum Tax PDF Author: Allison Christians
Publisher:
ISBN:
Category :
Languages : en
Pages : 0

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Book Description
This Guide seeks to provide information helpful to countries making policy decisions with respect to the Pillar Two Global Anti-Base Erosion (GloBE) minimum tax proposal. The GloBE initiative creates a pool of potential tax revenues on in-scope corporate multinationals' incomes to be collected by GloBE participating countries (that host an entity in the MNE group) whenever the effective tax rate of an entity (or entities) within the MNE group in the country falls below 15 percent. Some domestic tax measures intended to attract and keep foreign investment may lose their effectiveness as a result. Further, some of GloBE's impact may be indirect, providing lawmakers with an opportunity to consider policy reforms whether or not they adopt GloBE itself. It is in the interest of each country to examine the potential applicability of GloBE to its taxpayers and the interplay of GloBE rules with its domestic tax system in order to make informed decisions about whether and in what manner to respond.

The Proposal for a Global Minimum Tax : Comeback of Residence Taxation in the Digital Era? Comment on Can GILTI + BEAT

The Proposal for a Global Minimum Tax : Comeback of Residence Taxation in the Digital Era? Comment on Can GILTI + BEAT PDF Author: D.W. Blum
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
The article reflects on the article by M. Herzfeld "Can GILTI + BEAT = GLOBE?" on using the USA tax reforms rules as a model for global minimum tax.