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Assessing the impact of Pillar Two on developing countries Suranjali Tandon

By: Tandon, Suranjali.
Material type: ArticleArticleSubject(s): FISCALIDAD INTERNACIONAL | SEGUNDO PILAR (OCDE) | IMPUESTO DE SOCIEDADES | TIPO MÍNIMO GLOBAL | APLICACION | INCENTIVOS FISCALES | PAISES EN DESARROLLO In: Intertax v. 50, n. 12, December 2022, p. 923-935Summary: The Pillar Two reform is designed to end the four decade long race to the bottom that persisted despite the minimum standards and best practices promoted by the Base Erosion and Profit Shifting (BEPS) Program. However, in the process of mending the inadequate international tax system, the OECD changed its agenda to addressing tax competition. With a wide objective of increasing the effective tax rates across jurisdictions to 15%, it disregards the constraints that it imposes on developing countries. This article demonstrates that the immediate revenue gains of developing countries remain limited, and the tax will restrict the ability to offer tax incentives and will undermine the sovereignty of states in its application to some extent.
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Resumen.

The Pillar Two reform is designed to end the four decade long race to the bottom that persisted despite the minimum standards and best practices promoted by the Base Erosion and Profit Shifting (BEPS) Program. However, in the process of mending the inadequate international tax system, the OECD changed its agenda to addressing tax competition. With a wide objective of increasing the effective tax rates across jurisdictions to 15%, it disregards the constraints that it imposes on developing countries. This article demonstrates that the immediate revenue gains of developing countries remain limited, and the tax will restrict the ability to offer tax incentives and will undermine the sovereignty of states in its application to some extent.

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