International Effective Minimum Taxation – analysis of GloBE (Pillar Two)

Abstract

The G20/OECD Inclusive Framework is currently deliberating an effective international minimum tax as Pillar Two of its work on the tax challenges arising from digitalization. Political agreement on the so-called Global Anti-Base Erosion Proposal (GloBE) is sought for summer 2021 and prospects currently look good, in particular due to its full endorsement by the Biden administration. This paper outlines the developments leading up to the October 2020 Blueprint on GloBE and provides an assessment of its policy rationale and of certain objections raised in public hearings and in literature. Moreover, the paper critically analyses some of GloBE’s key design features; it also shortly addresses its compatibility with tax treaty law and simplification measures.

This paper will be published in the OUP Handbook of International Tax Law (F. Haase, G. Kofler eds., Oxford University Press 2021 forthcoming)

Keywords: Pillar Two, minimum taxation, G20/OECD Inclusive Framework, digital economy, international taxation

JEL Classification: H25, H26, K34