The ‘Pillar Two’ Global Minimum Tax

Hardback

The ‘Pillar Two’ Global Minimum Tax

9781035308736 Edward Elgar Publishing
Edited by Werner Haslehner, ATOZ Chair for European and International Tax Law, University of Luxembourg, Luxembourg, Georg Kofler, Professor of International Tax Law, Institute for Austrian and International Tax Law, Vienna University of Economics and Business, Austria, Katerina Pantazatou, Associate Professor of Tax Law, University of Luxembourg, Luxembourg and Alexander Rust, Professor of Tax Law, Institute for Austrian and International Tax Law, Vienna University of Economics and Business, Austria
Publication Date: August 2024 ISBN: 978 1 03530 873 6 Extent: c 354 pp
Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.

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Critical Acclaim
Contents
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Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic, and political context, but the book also explores the intricate technical detail of the GloBE model rules.

Key Features:

● Exploration of the Pillar Two proposal’s formative development
● Detailed discussion of key concepts such as process legitimacy
● Examination of the Pillar Two objectives and the reasons which led to its adoption
● Assessment of the interaction between the GloBE rules and national law, European law, and existing bilateral tax treaties
● Consideration of the impact of the new regime on multinational businesses and the future interaction of states through tax competition
● Step-by-step analysis of the complex set of GloBE model rules that have been put in place to make the minimum taxation regime effective

This authoritative book is an essential resource for legal practitioners practising in tax law, fiscal policy, and commercial law. The applied nature of the text is also of great benefit to policymakers working in the taxation sphere. Scholars and students of international taxation will similarly find this to be a useful reference.
Critical Acclaim
‘The ‘Pillar Two’ Global Minimum Tax is an important and timely work bringing together new essays on a topic that has engaged the international tax community over recent years. With contributions from some of the most prominent researchers on international taxation, this book tackles a rich variety of perspectives ranging from normative analysis, through the procedural and political aspects of the issue, to some important technical analyses of the mechanics of Pillar Two. This book is bound to become a key point of reference for anyone working on the subject or studying it.''
– Tsilly Dagan, University of Oxford, UK

‘This engaging book, featuring contributions from European tax experts, examines Pillar Two from what seems to be every conceivable perspective. The volume’s panoptic approach yields surprising insights with respect to the issues likely to emerge from the OECD’s radical reformulation of the rules of international taxation.’
– David Rosenbloom, Caplin & Drysdale, US
Contents
Contents

1 Formative politics and policies of Pillar Two 1
Richard Collier and John Vella
2 The economics and impact of Pillar Two 28
Giuseppe Pulina and Skerdilajda Zanaj
3 The business perspective on the Pillar Two global minimum tax 47
Ulrike Schramm and Arne Dettling
4 The perceived (un)fairness of the global minimum corporate tax rate 58
Rita de la Feria
5 The scope of Pillar Two 84
Cécile Brokelind
6 Computation of GloBE income or loss 104
Nupur Jalan
7 Computation of the effective tax rate and the ‘top-up tax’ 135
Valentin Bendlinger and Georg Kofler
8 The income inclusion rule and the undertaxed profits rule 205
Alexia Kardachaki and Sjoerd Douma
9 A simplification safe harbour for Pillar Two 242
Cedric Döllefeld, Joachim Englisch, Simon Harst, Deborah Schanz and Feli Siegel
10 Tax neutrality regimes and GloBE 260
Leopoldo Parada
11 The Pillar Two top-up taxes and tax treaties 282
Ana Paula Dourado
12 Pillar Two and EU law 304
Katerina Pantazatou
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