The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant ref...The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.展开更多
The United States has not yet enacted,or even considered,any legislation designed to implement either of the two pillars in the OECD/G20's two-pillar global tax plan.This article discusses the reasons for this ina...The United States has not yet enacted,or even considered,any legislation designed to implement either of the two pillars in the OECD/G20's two-pillar global tax plan.This article discusses the reasons for this inaction and the prospects for any action by the United States in the future.After reviewing the events that have brought us to the current state of affairs,the discussion considers the Biden Administration's proposals regarding Pillar One and Pillar Two,both internationally(i.e.,in negotiations with other members of the Inclusive Framework)and domestically(i.e.,in the US political and legislative process).The article concludes that it should not be surprising that the US is going its own way in the multilateral tax process.展开更多
文摘The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.
文摘The United States has not yet enacted,or even considered,any legislation designed to implement either of the two pillars in the OECD/G20's two-pillar global tax plan.This article discusses the reasons for this inaction and the prospects for any action by the United States in the future.After reviewing the events that have brought us to the current state of affairs,the discussion considers the Biden Administration's proposals regarding Pillar One and Pillar Two,both internationally(i.e.,in negotiations with other members of the Inclusive Framework)and domestically(i.e.,in the US political and legislative process).The article concludes that it should not be surprising that the US is going its own way in the multilateral tax process.
