Implementing a (global?) minimum corporate income tax
An assessment of the so-called "Pillar Two" from the perspective of developing countries
Keywords:corporate income tax, global minimum tax, Pillar Two, BEPS, tax competition, developing countries
Almost eight years have passed since the BEPS Action Plan was launched by the OECD and Action 1 identified corporate income tax challenges derived from the digitalization of the economy as a relevant area to be addressed. As from January 2019, the stream of work at the OECD has changed. Apparently, a novel era - “BEPS 2.0” - has begun under the slogan of working on a “without prejudice” basis and a two-pillar approach with the aim of reaching an agreement on a global solution. Though the author recognizes the need to find a coordinated answer, she believes that in the construction of said solution, attention should be given to specific features and policy preferences evidenced by developing countries. Under this scenario, this contribution focuses on the so-called “Pillar Two” and assesses its “Global Anti-Base Erosion (GloBE) proposal” from said perspective. After her analysis, the author concludes that this rushed political-driven proposal not only has been designed in the benefit of major and more advanced economies, but it goes far more beyond “BEPS”. In this vein, the author advocates for concentrating the efforts and resources on a transparent discussion that directly addresses efficient and fairer nexus and profit allocation rules – main concern for developing countries and, in the autor´s view, the base problem to be solved.
Copyright (c) 2021 Andrea Riccardi
This work is licensed under a Creative Commons Attribution 4.0 International License.
NJOLAS is an open access journal, which means that all content is freely available without charge to the user. Users are allowed to read, download, copy, distribute, print, search, or link to the full texts of the articles featured in the journal without asking prior permission from the publisher or the author. This is in accordance with definition of open access as formulated by the Budapest Open Access Initiative (BOAI).
All authors who publish in this journal agree to the following terms:
- Authors retain copyright and grant NJOLAS the right of first publication. The work is licensed under Creative Commons Attribution License (http://creativecommons.org/licenses/by/4.0/), which allows others to share and distribute the work as long as it is attributed to the author and its initial publication in NJOLAS is acknowledged.
- Authors are encouraged to distribute the work themselves with information on its initial publication in NJOLAS, e.g. upload it to open repositories linked to their personal website or institutional affiliation.