International corporate tax regime post-BEPS a regulatory perspective Stjepan Gadzo & Sime Jozipovic
By: Gadzo, Stjepan
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Contributor(s): Jozipovic, Sime.
Material type: 
ArticlePublisher: 2020Subject(s): FISCALIDAD INTERNACIONAL | COMPETENCIA FISCAL NOCIVA | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | PROGRAMAS | ELUSION FISCAL | EVASION FISCAL | CONTROL | SEGUNDO PILAR (OCDE)
In:
Intertax v. 48, Issue 4, April 2020, p. 432-445Summary: This article explores the recent attempts to overhaul the international tax regime from the regulatory perspective. The regulatory perspective is understood here as the capacity of the rules of international tax law to affect the behaviour of both corporate taxpayers in arranging their cross-border activities and the States in designing their CIT systems. The BEPS initiative serves as a prime example of how international tax law fulfils its regulatory function, by guiding the behaviour of both governments and taxpayers. Accordingly, the paper argues that the international corporate tax regime post-BEPS exhibits two sides of the same regulatory coin: on the one hand, taxpayers are disincentivized to resort to particular types of international tax planning; on the other, the incentives for individual States to engage in corporate tax competition are significantly reduced. It is further argued that the most far-reaching proposal in this area relates to 'global minimum tax', drawn under Pillar Two of the 'BEPS 2.0' initiative.
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| Artículos | IEF | IEF | OP 2141/2020/4-7 (Browse shelf) | Available | OP 2141/2020/4-7 |
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| OP 2141/2020/4-4 Positive spillovers in international corporate taxation and the European Union | OP 2141/2020/4-5 The vagueness of tax fairness | OP 2141/2020/4-6 How countervailing measures could be used to limit strategic tax competition | OP 2141/2020/4-7 International corporate tax regime post-BEPS | OP 2141/2020/4-8 Regulatory framework for tax incentives in developing countries after BEPS Action 5 | OP 2141/2020/48-13 COVID-19 and US Tax Policy | OP 2141/2020/48-16 Unnecessary and yet harmful |
Resumen.
This article explores the recent attempts to overhaul the international tax regime from the regulatory perspective. The regulatory perspective is understood here as the capacity of the rules of international tax law to affect the behaviour of both corporate taxpayers in arranging their cross-border activities and the States in designing their CIT systems. The BEPS initiative serves as a prime example of how international tax law fulfils its regulatory function, by guiding the behaviour of both governments and taxpayers. Accordingly, the paper argues that the international corporate tax regime post-BEPS exhibits two sides of the same regulatory coin: on the one hand, taxpayers are disincentivized to resort to particular types of international tax planning; on the other, the incentives for individual States to engage in corporate tax competition are significantly reduced. It is further argued that the most far-reaching proposal in this area relates to 'global minimum tax', drawn under Pillar Two of the 'BEPS 2.0' initiative.
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