State Strategic Responses to the GloBE Rules

44 Pages Posted: 15 Dec 2022

See all articles by Heydon Wardell-Burrus

Heydon Wardell-Burrus

Oxford University Centre for Business Taxation; University of Oxford - Faculty of Law

Date Written: December 1, 2022


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

Suggested Citation

Wardell-Burrus, Heydon, State Strategic Responses to the GloBE Rules (December 1, 2022). Available at SSRN: or

Heydon Wardell-Burrus (Contact Author)

Oxford University Centre for Business Taxation ( email )

Saïd Business School
Park End Street
Oxford, OX1 1HP
United Kingdom

University of Oxford - Faculty of Law ( email )

3 Worcester Street
Christ Church
Oxford, OX1 2BX
United Kingdom

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