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Some EU and tax treaty law considerations on the draft EU Directive on Global Minimum Taxation for Multinationals in the Union Luc De Broe

By: De Broe, Luc.
Material type: ArticleArticleSubject(s): FISCALIDAD INTERNACIONAL | SEGUNDO PILAR (OCDE) | EMPRESAS MULTINACIONALES | IMPUESTO DE SOCIEDADES | TIPO MÍNIMO GLOBAL | APLICACION | DERECHO COMUNITARIO EUROPEO | UNION EUROPEA In: Intertax v. 50, n. 12, December 2022, p. 874-887Summary: In this article the author examines whether the draft EU Directive on Global Minimum Taxation for Multinationals complies with primary Union and whether the GloBE Model rules comply with the commitments undertaken by jurisdictions under their bilateral tax treaties that follow the OECD Model. Suggestions are also made on how the prevention and resolution of disputes under the Globe Model rules can be improved.
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Resumen.

In this article the author examines whether the draft EU Directive on Global Minimum Taxation for Multinationals complies with primary Union and whether the GloBE Model rules comply with the commitments undertaken by jurisdictions under their bilateral tax treaties that follow the OECD Model. Suggestions are also made on how the prevention and resolution of disputes under the Globe Model rules can be improved.

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