GloBE: Do We Need a Super-CFC? (Forthcoming: Intertax, Vol. 49, 2021, Issue 1)
Since the OECD introduced its Global Anti-Base Erosion Proposal (GLoBE) in early 2019 as the second pillar of the ongoing search for a solution to the tax challenges of the Digitalisation of the economy, the goal of GloBE seems to be moving. On the one hand, already the name suggests that the proposal for a…