Global Minimum Taxation
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The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law
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Author : Valentin Bendlinger
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-10-17
The Oecd S Global Minimum Tax And Its Implementation In The Eu A Legal Analysis Of Pillar Two In The Light Of Tax Treaty And Eu Law written by Valentin Bendlinger and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-10-17 with Law categories.
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.
Global Minimum Taxation
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Author :
language : en
Publisher:
Release Date : 2021
Global Minimum Taxation written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021 with categories.
The Pillar Two Global Minimum Tax
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Author : Werner Haslehner
language : en
Publisher:
Release Date : 2024-08-28
The Pillar Two Global Minimum Tax written by Werner Haslehner and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-08-28 with Law categories.
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. Key Features: Exploration of the Pillar 2 proposal's formative development Detailed discussion of key concepts such as process legitimacy Examination of the Pillar 2 objectives and the reasons which led to its adoption Assessment of the interaction between the GloBE rules and national law, European law and existing bilateral tax treaties Consideration of the impact of the new regime on multinational businesses and the future interaction of states through tax competition Step-by-step analysis of the complex set of GloBE model rules that have been put in place to make the minimum taxation regime effective This authoritative book is an essential resource for legal practitioners practising in tax law, fiscal policy and commercial law. The applied nature of the text is also of great benefit to policymakers working in the taxation sphere. Scholars and students of international taxation will similarly find this to be a useful reference.
Efficient Economic Rent Taxation Under A Global Minimum Corporate Tax
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Author : Mr. Shafik Hebous
language : en
Publisher: International Monetary Fund
Release Date : 2024-03-15
Efficient Economic Rent Taxation Under A Global Minimum Corporate Tax written by Mr. Shafik Hebous and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-03-15 with Business & Economics categories.
The international agreement on a corporate minimum tax is a milestone in global corporate tax arrangements. The minimum tax disturbs the equivalence between otherwise equivalent forms of efficient economic rent taxation: cash-flow tax and allowance for corporate equity. The marginal effective tax rate initially declines as the statutory tax rate rises, reaching zero where the minimum tax is inapplicable, and increases thereafter. This kink occurs at a lower statutory rate under cash-flow taxation. We relax the assumption of full loss offset; provide a routine for computing effective rates under different designs; and discuss policy implications of the minimum tax.
The Oecd Globe Proposal A Decisive Step Towards Uniform Global Minimum Taxation
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Author : Magdalena Schwarz
language : en
Publisher:
Release Date : 2022-10-31
The Oecd Globe Proposal A Decisive Step Towards Uniform Global Minimum Taxation written by Magdalena Schwarz and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-10-31 with categories.
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.
A Firm Lower Bound Characteristics And Impact Of Corporate Minimum Taxation
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Author : Aqib Aslam
language : en
Publisher: International Monetary Fund
Release Date : 2021-06-08
A Firm Lower Bound Characteristics And Impact Of Corporate Minimum Taxation written by Aqib Aslam and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-08 with Business & Economics categories.
This paper examines the role of minimum taxes and attempts to quantify their impact on economic activity. Minimum taxes can be effective at shoring up the corporate tax base and enhancing the perceived equity of the tax system, potentially motivating broader taxpayer compliance. Where political and administrative constraints prevent reforms to the standard corporate income tax, a minimum tax can help mitigate base erosion from excessive tax incentives and avoidance. Using a new panel dataset that catalogues changes in minimum tax regimes over time around the world, firm-level analysis suggests that the introduction or reform of a minimum tax is associated with an increase in the average effective tax rate of just over 1.5 percentage points with respect to turnover and of around 10 percent with respect to operating income. Minimum taxes based on modified corporate income lead to the largest increases in effective tax rates, followed by those based on assets and turnover.
The Oecd Globe Proposal A Decisive Step Towards Uniform Global Minimum Taxation
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Author : Schwarz
language : en
Publisher:
Release Date : 2022
The Oecd Globe Proposal A Decisive Step Towards Uniform Global Minimum Taxation written by Schwarz and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022 with categories.
Pareto Improving Minimum Corporate Taxation
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Author : Mr. Shafik Hebous
language : en
Publisher: International Monetary Fund
Release Date : 2021-10-22
Pareto Improving Minimum Corporate Taxation written by Mr. Shafik Hebous and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-10-22 with Business & Economics categories.
The recent international agreement on a minimum effective corporate tax rate marks a profound change in global tax arrangements. The appropriate level of that minimum, however, has been, and remains, extremely contentious. This paper explores the strategic responses to a minimum tax, which—the policy objective being to change the rules of tax competition game--—are critical for assessing the design and welfare impact of, and prospects for, this fundamental policy innovation. Analysis and calibration plausibly suggest sizable scope for minima that are Pareto-improving, benefiting low as well as high tax countries, over the uncoordinated equilibrium.
International Tax Spillovers And Tangible Investment With Implications For The Global Minimum Tax
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Author : Mr. Michael Keen
language : en
Publisher: International Monetary Fund
Release Date : 2023-08-04
International Tax Spillovers And Tangible Investment With Implications For The Global Minimum Tax written by Mr. Michael Keen and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-08-04 with Business & Economics categories.
This paper articulates and, using newly-assembled data, explores how international taxation affects aggregate tangible cross-border investment. Spillovers from statutory tax rates abroad seem: As sizable as effects from the host’s rate; larger than previous consensus values (attributed to a systematic bias from FDI data); and consistent with ‘implicit’ profit shifting through real investment (rather than ‘paper’ profit shifting). Contrary to much policy discussion, the results also imply that: Host countries’ marginal effective tax rates have at best a weak effect on real investment; those elsewhere have none; and, applied to the prospective global minimum tax, inward tangible investment in most sample countries will increase.
Coordination And Cooperation
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Author : Brigitte Alepin
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-11-25
Coordination And Cooperation written by Brigitte Alepin and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-11-25 with Law categories.
Series on International Taxation #81 The tax landscape today looks dramatically different from how it appeared even a generation ago. Ongoing sweeping changes in information technologies, massive economic downturns, unforeseen catastrophes such as the global pandemic that hit the world in 2020, and ever more sophisticated methods of tax evasion and avoidance are only some of the factors that have perplexed and even confounded tax authorities. This important book provides a comprehensive overview of the global tax challenges confronting tax policy today, with insightful contributions by both well-known tax experts and fresh new voices in the field. The authors address such critical issues as the following: international tax reform initiatives; effects of climate change; tax justice in times of crisis; international tax cooperation; taxing multinationals; role of tax havens; participation and collaboration of developing countries; the growing presence of artificial intelligence and robots; prospects for a green economic recovery; and tax ethics and social inclusiveness. The contributions originated with the groundbreaking tax summit TaxCOOP2020, held online at the peak of the Covid-19 pandemic in October 2020. At a time when tax policy seems poised at the dawn of a fundamental transformation, this inestimable volume will be welcomed by tax practitioners and academics, concerned government officials, businesspeople, international organizations, and non-governmental organizations (NGOs), all of whom will here have access to a variety of points of view and innovative approaches to the future direction of taxation.