A Guide for Developing Countries on How to Understand and Adapt to the Global Minimum Tax: Draft for Consultation

Abstract

This Guide seeks to provide information helpful to countries making policy decisions with respect to the Pillar Two Global Anti-Base Erosion (GloBE) minimum tax proposal. The GloBE initiative creates a pool of potential tax revenues on in-scope corporate multinationals’ incomes to be collected by GloBE participating countries (that host an entity in the MNE group) whenever the effective tax rate of an entity (or entities) within the MNE group in the country falls below 15 percent. Some domestic tax measures intended to attract and keep foreign investment may lose their effectiveness as a result. Further, some of GloBE’s impact may be indirect, providing lawmakers with an opportunity to consider policy reforms whether or not they adopt GloBE itself. It is in the interest of each country to examine the potential applicability of GloBE to its taxpayers and the interplay of GloBE rules with its domestic tax system in order to make informed decisions about whether and in what manner to respond.

Keywords: taxation, development, economics, tax treaties, bilateral investment treaties, BITs, trade, stabilization, corporate tax, minimum taxes, globe, pillar 2

JEL Classification: D78, E62, F02, F23, F24, H20, H25, H77, H87, K33, K34, O38