The 'Pillar Two' Global Minimum Tax

Edited by: Werner Haslehner, Georg Kofler, Katerina Pantazatou, Alexander Rust

Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. It considers this unprecedented diplomatic achievement in its historic, economic and political context, and explores the intricate technical detail of the GloBE model rules.

Key Features: exploration of the Pillar 2 proposal's formative development; detailed discussion of process legitimacy; assessment of the interaction between the GloBE rules and national law, European law and existing bilateral tax treaties; consideration of the impact on multinational businesses and future tax competition; step-by-step analysis of the GloBE model rules.

Contents: Formative Politics and Policies of Pillar Two; The Economics and Impact of Pillar Two; The Business Perspective; The Scope of Pillar Two; Computation of GloBE Income or Loss; Computation of the Effective Tax Rate and the 'Top-Up Tax'; The Income Inclusion Rule and the Undertaxed Profits Rule; A Simplification Safe Harbour; Tax Neutrality Regimes and GloBE; Pillar Two Top-Up Taxes and Tax Treaties; Pillar Two and EU Law.

Where can I buy The 'Pillar Two' Global Minimum Tax?

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Q&A

Who is this book for?
Legal practitioners in tax law, fiscal policy and commercial law, plus policymakers, scholars and students of international taxation.

What does the book cover in depth?
The GloBE model rules step-by-step, and how Pillar Two interacts with national law, EU law and existing bilateral tax treaties.

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