Global Minimum Taxation?

An Analysis of the Global Anti-Base Erosion Initiative

Global Minimum Taxation?
This book addresses the ongoing debate surrounding convergence towards global minimum taxation heralded by the proposed GloBE framework and connected rules in light of the Pillar Two Blueprint Report.

Why this book?

The Global Anti-Base Erosion (GloBE) proposal entails what may constitute the greatest shift in the international tax regime since its inception. GloBE is meant to focus on the “remaining BEPS issues and seeks to develop rules that would provide jurisdictions with a right to ‘tax back’ where other jurisdictions have not exercised their primary taxing rights or the payment is otherwise subject to low levels of effective taxation”. First proposed in early 2019, this corollary to the BEPS Project – sometimes referred to as “BEPS 2.0” – has been in the international spotlight and pressed ahead with unprecedented speed.

This book addresses the ongoing debate surrounding convergence towards global minimum taxation heralded by the proposed GloBE framework and connected rules in light of the specifications offered by the October 2020 Pillar Two Blueprint Report.

It covers not only the design and technical aspects of the Pillar Two package, addressing in depth each of the proposed rules (income inclusion, undertaxed payments, switchover and subject-to-tax), but also their interaction and certain overarching issues such as the determination of the minimum effective tax rate and the design of a global tax base.

Furthermore, the book approaches the proposed rules dynamically, setting them against the backdrop of key legal and policy frameworks, such as: tax treaties, transfer pricing, EU law and US rules, such as GILTI and BEAT. Then, the book considers broader policy issues concerning the prospective implementation of the proposed rules, also by providing a specific focus on the challenges and opportunities for developing countries. By way of conclusion, the volume addresses the interaction between the debates on Pillar Two and Pillar One, including the potential for simplification of the proposed rules.

Global Minimum Taxation? An Analysis of the Global Anti-Base Erosion Initiative constitutes essential reading for practitioners, students and policymakers, trying as it does to bring together the two complementary needs of ensuring the most up-to-date and topical coverage of this momentous turning point in international taxation with the necessary depth of analysis and the “big picture” view that should always inspire any research pursuit.

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This book is part of the IBFD Tax Research Series

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Editor(s)

Andreas Perdelwitz and Alessandro Turina

Contributor(s)

Vasiliki Agianni, Mery Alvarado, Betty Andrade Rodríguez, Francesco De Lillo, Jean-Edouard Duvauchelle, Giulia Gallo, Larisa Gerzova, Johan Hagelin, Diana Calderón Manrique, Sabrine Marsit, Teresa Morales, Luis Nouel, João Félix Pinto Nogueira, Belema R. Obuoforibo, René Offermanns, Pasquale Pistone, Andreas Perdelwitz, Oana Popa, John G. Rienstra, Benjamin Rodriguez, Marnix Schellekens, Alessandro Turina.

Global Minimum Taxation?
https://doi.org/10.59403/1vkve22
Chapter 1: Introducing Pillar Two: Towards a Global Minimum Effective Tax Rate
https://doi.org/10.59403/1vkve22001
Chapter 2: The GloBE Tax Base: Road to the Jurisdictional Effective Tax Rate
https://doi.org/10.59403/1vkve22002
Chapter 3: The Income Inclusion Rule
https://doi.org/10.59403/1vkve22003
Chapter 4: The Switch-Over Rule
https://doi.org/10.59403/1vkve22004
Chapter 5: The Undertaxed Payments Rule
https://doi.org/10.59403/1vkve22005
Chapter 6: The Subject-to-Tax Rule
https://doi.org/10.59403/1vkve22006
Chapter 7: Coordination and Rule Order
https://doi.org/10.59403/1vkve22007
Chapter 8: Interaction of Pillar Two with Tax Treaties
https://doi.org/10.59403/1vkve22008
Chapter 9: Pillar Two and Transfer Pricing
https://doi.org/10.59403/1vkve22009
Chapter 10: Pillar Two and EU Law
https://doi.org/10.59403/1vkve22010
Chapter 11: Pillar Two from the US Perspective
https://doi.org/10.59403/1vkve22011
Chapter 12: The Pillar Two Initiative and Developing Countries
https://doi.org/10.59403/1vkve22012
Chapter 13: The Implementation of Pillar Two
https://doi.org/10.59403/1vkve22013
Chapter 14: The Way Ahead: Policy Consistency and Sustainability of the GloBE Proposal
https://doi.org/10.59403/1vkve22014