Global miniumum tax

CFC regime, Global miniumum tax, GloBE, Japan

(Nishimura & Asahi (Tokyo))/ /Leave a comment

Some OECD officials have reportedly noted that countries should consider changing or eliminating potentially duplicative anti-avoidance measures, such as CFC legislation when they implement the 15% global minimum tax rules (or the so-called GloBE rules proposed by the OECD).[1] This blog will overview the German approach, which seems in line with this view, and the…

ETR, Global miniumum tax

, (University of Muenster)/ /Leave a comment

Johannes Becker and Joachim Englisch* After the international political agreement to introduce an effective country-by-country minimum tax on multinational firm profits, there are still some open questions on the design and implementation of the tax[1]. Among other elements, the OECD/G20 Inclusive Framework Statement of 8 October 2021 envisages a “formulaic substance carve-out” for deemed routine…