Download or read book Taxing Multinationals the GloBE Proposal for a Global Minimum Tax written by L. Eden and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Effective Minimum Taxation the GLOBE Proposal written by J. Englisch and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Effective Minimum Taxation The GLOBE Proposal written by Joachim Englisch and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book The Pillar Two Global Minimum Tax written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2024-08-06 with total page 353 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book The OECD GloBE Proposal a Decisive Step Towards Uniform Global Minimum Taxation written by Magdalena Schwarz and published by . This book was released on 2022-10-31 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Potential Repsonse to GLOBE Domestic Minimum Taxes in Countries Affected by the Global Minimum Tax written by N. Noked and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
Download or read book The OECD GloBE proposal a decisive step towards uniform global minimum taxation written by Schwarz and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Guide for Developing Countries on How to Understand and Adapt to the Global Minimum Tax written by Allison Christians and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book The Proposal for a Global Minimum Tax Comeback of Residence Taxation in the Digital Era Comment on Can GILTI BEAT written by D.W. Blum and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book GLOBAL MINIMUM TAXATION written by and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Deciphering the GloBE in a Low Tax Jurisdiction written by Mr. Shafik Hebous and published by International Monetary Fund. This book was released on 2024-03-22 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Tax Sparing written by Organisation for Economic Co-operation and Development and published by Org. for Economic Cooperation & Development. This book was released on 1998 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report examines the practices of Member countries with regards to tax sparing and explains why Member countries have become more reluctant to grant tax sparing in treaties. It also provides a number of suggested "best practices" on the design of tax sparing provisions in tax treaties.
Download or read book Designing Domestic Minimum Taxes in Response to the Global Minimum Tax written by Noam Noked and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Countries may soon adopt domestic minimum taxes in response to the global minimum tax under the Global Anti-Base Erosion (GloBE) regime. These taxes, which will have priority over the global minimum tax under GloBE, could become the primary measure of ensuring that multinational enterprises (MNEs) pay a minimum level of tax. Despite their expected importance, the GloBE Model Rules and Commentary provide little guidance on several important design and policy issues concerning domestic minimum taxes. This article analyses the relevant rules in the Model Rules and the guidance in the Commentary. It also explores several questions that the OECD and the GloBE Implementation Framework should consider regarding the design of domestic minimum taxes and related issues such as collateral benefits.
Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Download or read book A Firm Lower Bound Characteristics and Impact of Corporate Minimum Taxation written by Aqib Aslam and published by International Monetary Fund. This book was released on 2021-06-08 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Corporate Tax Avoidance A Review of the Channels Magnitudes and Blind Spots written by Sebastian Beer and published by International Monetary Fund. This book was released on 2018-07-23 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
