International Effective Minimum Taxation – The GLOBE Proposal

Abstract

In its Public Consultation Document, the OECD discusses the introduction of effective minimum taxes on multinational firm profits (the so-called GLOBE: "global anti-base erosion" proposal). In this paper, we make three distinct contributions. First, we discuss the policy rationale for the minimum tax, its advantages and potential problems. Second, we analyse important features of tax design, i.e. the technical dimension of the tax. Third, we examine the proposal in the legal and economic context of the complementary proposals that are currently under discussion (the "Pillar 1" proposals for a reallocation of taxing rights) and its compatibility with tax treaty law and EU treaty law.

Keywords: Minimum Taxation, Multinational Firms, GLOBE

JEL Classification: H25, F23