The 'Pillar Two' Global Minimum Tax

Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.

Key Features:

• Exploration of the Pillar 2 proposal’s formative development
• Detailed discussion of key concepts such as process legitimacy
• Examination of the Pillar 2 objectives and the reasons which led to its adoption
• Assessment of the interaction between the GloBE rules and national law, European law and existing bilateral tax treaties
• Consideration of the impact of the new regime on multinational businesses and the future interaction of states through tax competition
• Step-by-step analysis of the complex set of GloBE model rules that have been put in place to make the minimum taxation regime effective

This authoritative book is an essential resource for legal practitioners practising in tax law, fiscal policy and commercial law. The applied nature of the text is also of great benefit to policymakers working in the taxation sphere. Scholars and students of international taxation will similarly find this to be a useful reference.

Contents:

1. Formative politics and policies of Pillar Two 1
Richard Collier and John Vella
2. The economics and impact of Pillar Two 28
Giuseppe Pulina and Skerdilajda Zanaj
3. The business perspective on the Pillar Two global minimum tax 47
Ulrike Schramm and Arne Dettling
4. The perceived (un)fairness of the global minimum corporate tax rate 58
Rita de la Feria
5. The scope of Pillar Two 84
Cécile Brokelind
6. Computation of GloBE income or loss 104
Nupur Jalan
7. Computation of the effective tax rate and the ‘top-up tax’ 135
Valentin Bendlinger and Georg Kofler
8. The income inclusion rule and the undertaxed profits rule 205
Alexia Kardachaki and Sjoerd Douma
9. A simplification safe harbour for Pillar Two 242
Cedric Döllefeld, Joachim Englisch, Simon Harst, Deborah Schanz and Feli Siegel
10. Tax neutrality regimes and GloBE 260
Leopoldo Parada
11. The Pillar Two top-up taxes and tax treaties 282
Ana Paula Dourado
12. Pillar Two and EU law 304
Katerina Pantazatou