The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of ...The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of a dispute prevention and resolution framework for the GloBE rules faces significant challenges.This article offers two possible options for an effective dispute prevention and resolution mechanism:a model based on reciprocal domestic legislations and the multilateral convention model.展开更多
The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant ref...The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.展开更多
文摘The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of a dispute prevention and resolution framework for the GloBE rules faces significant challenges.This article offers two possible options for an effective dispute prevention and resolution mechanism:a model based on reciprocal domestic legislations and the multilateral convention model.
文摘The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.
