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
Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax administrations.Therefore,it has been considered as one of the core ...Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax administrations.Therefore,it has been considered as one of the core areas by the BRITACOM parties.Over the past few years,considerable attention has been devoted to improving tax certainty while new challenges arise.This article analyses some of the recent advances and emerging initiatives in terms of raising tax certaintywww.britacom.org mechanisms for cross-border transactions in areas such as dispute prevention and resolution,transfer pricing,General Anti-Avoidance Rules(GAARs)and the taxation of digital economy.展开更多
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.
文摘Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax administrations.Therefore,it has been considered as one of the core areas by the BRITACOM parties.Over the past few years,considerable attention has been devoted to improving tax certainty while new challenges arise.This article analyses some of the recent advances and emerging initiatives in terms of raising tax certaintywww.britacom.org mechanisms for cross-border transactions in areas such as dispute prevention and resolution,transfer pricing,General Anti-Avoidance Rules(GAARs)and the taxation of digital economy.
