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Global Minimum Tax at a glance The OECD ́s Global Minimum Tax is amongst the most discussed topics in the recent international tax law debate. The book provides for more than 25 individual but co-ordinated essays on multiple relevant topics on Pillar Two is structured as follows: General Topics including the legal status of the GloBE Model Rules, their relation to tax treaties and EU Law, the GloBE STTR, the specifics of jurisdictional blending, their impact on tax competition and on tax incentives Scoping topics including the computation of the EUR 750 million threshold, the definition of MNE Group, territorial allocation of CEs and excluded entities Charging provisions, including GloBE ́s rule order and the impact of the GloBE Model Rules on minority shareholders Computation of GloBE Income and Loss, including contributions on the adjustment of permanent differences and specifics of dividends and equity gains for purposes of the base determination Computation of Adjusted Covered Taxes, including the notion of covered taxes, the recognition of temporal differences and the territorial allocation of covered taxes Top-up Tax computation including contributions on the general correspondence of covered taxes and GloBE Income, the Substance-Based Income Exclusion, the specifics of Investment and Minority-Owned Constituent Entities and the general role of the QDMTT within the framework of Pillar Two Selected topics on the administration of GloBE, e.g., Safe Harbors and the identification of the taxpayer within the framework of Pillar Two
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
This paper examines the role of minimum taxes and attempts to quantify their impact on economic activity. Minimum taxes can be effective at shoring up the corporate tax base and enhancing the perceived equity of the tax system, potentially motivating broader taxpayer compliance. Where political and administrative constraints prevent reforms to the standard corporate income tax, a minimum tax can help mitigate base erosion from excessive tax incentives and avoidance. Using a new panel dataset that catalogues changes in minimum tax regimes over time around the world, firm-level analysis suggests that the introduction or reform of a minimum tax is associated with an increase in the average effective tax rate of just over 1.5 percentage points with respect to turnover and of around 10 percent with respect to operating income. Minimum taxes based on modified corporate income lead to the largest increases in effective tax rates, followed by those based on assets and turnover.
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
This book addresses the ongoing debate surrounding convergence towards global minimum taxation heralded by the proposed GloBE framework and connected rules in light of the Pillar Two Blueprint Report.
Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.