Within hours of his appointment, Donald Trump issued a memorandum in which he rejects the Global Tax Deal conceived by the OECD/G20. The new US president stresses that it has “no force or effect within the United States” without an act by the Congress adopting the relevant provisions of the agreement. The memo is bluntly…
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…
Introduction In Fall 2021, almost 140 members of the Organisation for Economic Cooperation and Development (OECD) / Group of Twenty (G20) Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) — a framework for tackling tax planning strategies — agreed on a two-pillar solution, Pillar One and Pillar Two, to address the challenges arising…
