Revenue effects of the Global Minimum Tax under Pillar two Mona Baraké, Paul-Emmanuel Chouc, Theresa Neef & Gabriel Zucman
Contributor(s): Baraké, Mona
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Material type: 
ArticleSubject(s): SEGUNDO PILAR (OCDE) | EMPRESAS MULTINACIONALES | IMPUESTOS | TIPO MÍNIMO GLOBAL | RECAUDACION | APLICACION
In:
Intertax v. 50, n. 10, October 2022, p. 689-710Summary: The article present simulations of the revenue effects of the GloBE minimum tax. Two possible scenarios are considered, i.e., one in which the IIR is adopted by the headquarters country and another concerning the adoption of the QDMTT in source jurisdictions – the host country of the foreign MNE affiliates. Their analysis accentuates how the distribution of revenues varies depending on which country has the priority to collect them. Under the IIR, the more headquartered multinationals that a country has, the more revenues it receives. With the QDMTT that grants the host country the priority in collecting the top-up tax, low-tax jurisdictions that have attracted affiliates of many multinationals could be among the main beneficiaries of the reform. The authors also find that the least developed countries gain no or very limited revenues under either scenario.
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| OP 2141/2022/10 Intertax | OP 2141/2022/10-1 Pillar two under analysis | OP 2141/2022/10-2 Designing domestic minimum taxes in response to the Global Minimum Tax | OP 2141/2022/10-3 Revenue effects of the Global Minimum Tax under Pillar two | OP 2141/2022/10-4 Pillar two and African countries | OP 2141/2022/10-5 Addressing base erosion and profit shifting | OP 2141/2022/10-6 Right to a reasonable time during tax audits in Turkey |
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The article present simulations of the revenue effects of the GloBE minimum tax. Two possible scenarios are considered, i.e., one in which the IIR is adopted by the headquarters country and another concerning the adoption of the QDMTT in source jurisdictions – the host country of the foreign MNE affiliates. Their analysis accentuates how the distribution of revenues varies depending on which country has the priority to collect them. Under the IIR, the more headquartered multinationals that a country has, the more revenues it receives. With the QDMTT that grants the host country the priority in collecting the top-up tax, low-tax jurisdictions that have attracted affiliates of many multinationals could be among the main beneficiaries of the reform. The authors also find that the least developed countries gain no or very limited revenues under either scenario.
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