Download This PaperState Strategic Responses to the GloBE Rules
44 Pages Posted: 15 Dec 2022
Date Written: December 1, 2022
Abstract
The adoption of the GloBE Rules by a critical mass of countries will change the global tax competition landscape. States should be expected to respond by adopting strategies which have either been left open or have been newly created by the GloBE Rules. This paper considers how low tax states may respond by using timing benefits, refundable or transferable tax credits, tax equity partnerships, or shifting from a corporate income tax to a qualified domestic minimum top-up tax. It also considers strategies which are increasingly attractive under the GloBE Rules for high-tax states including bifurcating the tax system to attract mobile income and expanding their CFC rules. Finally, it addresses what can be done in response to these strategies either multilaterally (by the Inclusive Framework) or through strategic unilateral countermeasures.
Keywords: Pillar Two, Pillar 2, GloBE, Inclusive Framework
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- Usage
- Abstract Views: 1870
- Downloads: 799
- Captures
- Readers: 11
- Mentions
- Blog Mentions: 10
- News Mentions: 1