The GloBE income inclusion rule and its global character complexities underlying Its fully effective application Carla De Pietro
By: De Pietro, Carla
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Material type: 
ArticlePublisher: 2021Subject(s): TIPO MÍNIMO GLOBAL | APLICACION | ARMONIZACION FISCAL | SEGUNDO PILAR (OCDE)
In:
EC Tax Review v. 30, n. 5-6, December 2021, p. 220-235Summary: This article focuses on the complex challenges affecting the relationship between different tax systems (national, international and EU) within a context, like the current GloBE project, which is looking for appropriate tax measures applying on a global scale. In fact, the need of developing tax measures with a global character requires specific attention to be given to issues concerning the effectiveness of these measures in light of the relationship between the relevant tax systems. More specifically, within the framework of this article, the analysis aimed at evaluating the possibilities of guaranteeing a fully effective application of the GloBE income inclusion rule has been conducted on the basis of two crucial factors, i.e. (1) the compliance of the income inclusion rule with international tax treaty law and with EU tax law, and (2) the coordination between international tax treaty law and EU tax law.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141-B/2021/5/6-3 (Browse shelf) | Available | OP 2141-B/2021/5/6-3 |
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| OP 2141-B/2021/5/6 EC Tax Review | OP 2141-B/2021/5/6-1 On the evolving VAT concept of fixed establishment | OP 2141-B/2021/5/6-2 Non-harmonized implementation of a GloBE Minimum Tax | OP 2141-B/2021/5/6-3 The GloBE income inclusion rule and its global character | OP 2141-B/2021/5/6-4 The design of Covid-19 recovery contributions | OP 2141-B/2021/5/6-5 Article 6 ATAD and "non-genuineness" of arrangements | OP 2141-B/2021/5/6-6 The (absence of) Member State autonomy in the interpretation of DAC6 |
Resumen.
This article focuses on the complex challenges affecting the relationship between different tax systems (national, international and EU) within a context, like the current GloBE project, which is looking for appropriate tax measures applying on a global scale. In fact, the need of developing tax measures with a global character requires specific attention to be given to issues concerning the effectiveness of these measures in light of the relationship between the relevant tax systems. More specifically, within the framework of this article, the analysis aimed at evaluating the possibilities of guaranteeing a fully effective application of the GloBE income inclusion rule has been conducted on the basis of two crucial factors, i.e. (1) the compliance of the income inclusion rule with international tax treaty law and with EU tax law, and (2) the coordination between international tax treaty law and EU tax law.
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