The Pillar Two Global Minimum Tax
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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.
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.
The Oecd S Global Minimum Tax And Its Implementation In The Eu
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Author : Valentin Bendlinger
language : en
Publisher:
Release Date : 2023
The Oecd S Global Minimum Tax And Its Implementation In The Eu written by Valentin Bendlinger and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023 with categories.
Pillar 2 Global Minimum Tax
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Author : Gravelle
language : en
Publisher:
Release Date : 2022
Pillar 2 Global Minimum Tax written by Gravelle 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.
Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Report On Pillar Two Blueprint Inclusive Framework On Beps
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2020-10-14
Oecd G20 Base Erosion And Profit Shifting Project Tax Challenges Arising From Digitalisation Report On Pillar Two Blueprint Inclusive Framework On Beps written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-10-14 with categories.
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. This report explores options and issues in connection with the design of a global minimum tax that would address remaining BEPS issues.
Pillar Two Of The Inclusive Framework On Beps
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Author : Carlo Garbarino
language : en
Publisher:
Release Date : 2024-09-28
Pillar Two Of The Inclusive Framework On Beps written by Carlo Garbarino and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-09-28 with Law categories.
Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems. Key Features: Exploration of the scope of the GloBE Rules Accessible explanations of technical jargon accompanied by examples Focus on key concepts of GloBE income or loss and adjusted covered taxes Concise descriptions of each area of OECD policies on the global minimum tax Examination of domestic qualified minimum taxes that align with OECD standards Analysis of tax neutrality and distribution regimes This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book's expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.
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.
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.
International Corporate Tax Reform
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Author : International Monetary
language : en
Publisher: International Monetary Fund
Release Date : 2023-02-06
International Corporate Tax Reform written by International Monetary 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 2023-02-06 with Business & Economics categories.
To relieve the pressure on the outdated international corporate tax system, an ambitious reform was agreed at the Inclusive Framework (IF) on Base Erosion and Profit Shifting in 2021, with now 138 jurisdictions joining. It complements previous efforts to mitigate profit shifting by addressing the challenges of the digitalization of the economy through a new allocation of taxing rights to market economies (Pillar 1) and tax competition through a global minimum corporate tax (Pillar 2). This paper concludes that the agreement makes the international tax system more robust to tax spillovers, better equipped to address digitalization, and modestly raises global tax revenues.
Deciphering The Globe In A Low Tax Jurisdiction
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Author : Mr. Shafik Hebous
language : en
Publisher: International Monetary Fund
Release Date : 2024-03-22
Deciphering The Globe In A Low Tax Jurisdiction 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 2024-03-22 with Business & Economics categories.
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.