The Inclusive Framework’s Pillar Two rules aim to create a global tax system for multinational enterprises(MNEs).They propose a global minimum tax rate for MNEs to reduce profit shifting and ensure a minimum tax on g...The Inclusive Framework’s Pillar Two rules aim to create a global tax system for multinational enterprises(MNEs).They propose a global minimum tax rate for MNEs to reduce profit shifting and ensure a minimum tax on global income.The rules have been developed over the past years in order to provide for a coordinated and multilateral approach with common standards and mechanisms to avoid double taxation.However,the rules will need to be implemented by national laws,which may differ from the Model Rules and from each other causing distortions as national legislators have to adapt these rules to their own tax systems and contexts.This article explores how double taxation could arise from the different applications of the GloBE rules by different states.展开更多
文摘The Inclusive Framework’s Pillar Two rules aim to create a global tax system for multinational enterprises(MNEs).They propose a global minimum tax rate for MNEs to reduce profit shifting and ensure a minimum tax on global income.The rules have been developed over the past years in order to provide for a coordinated and multilateral approach with common standards and mechanisms to avoid double taxation.However,the rules will need to be implemented by national laws,which may differ from the Model Rules and from each other causing distortions as national legislators have to adapt these rules to their own tax systems and contexts.This article explores how double taxation could arise from the different applications of the GloBE rules by different states.
