GloBE Rules, IP, OECD, Tax Incentives

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

One strategic response of countries to the Global Minimum Tax (the GloBE rules) would be restructuring their tax incentives. The top-up tax effectively nullifies any tax incentive that brings the effective tax rate below 15%. This would push countries to redesign tax incentives that would otherwise produce an effective tax rate below 15%. In a…

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…