Inter-nation equity and the regulation of tax competition via the global minimum tax rule electrónico a case for improvement Chidozie Chukwudumogu
By: Chukwudumogu, Chidozie
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Material type: 
ArticleSubject(s): SEGUNDO PILAR (OCDE) | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO | INCENTIVOS FISCALES | COMPETENCIA FISCAL NOCIVA | FISCALIDAD INTERNACIONAL
In:
Intertax v.52, n.10, oct 2024, p.621 – 634Summary: This article submits that the Pillar Two minimum tax rule – the Global Anti-Base Erosion (GloBE) Rules encompassing the income inclusion rule (IIR), undertaxed payment/profit rule (UTPR), and qualified domestic minimum top-up tax (QDMTT) – should incorporate inter-nation equity to prevent exacerbating global inequality and poverty. Pillar Two intensifies these for at least two reasons: (1) it restricts the positive redistributive effects of tax competition on an inefficiently asymmetrical global society, and (2) it encourages tax competition more suited for high-income countries (HICs) and less suited for those that are low-income countries (LICs). There is latitude to incorporate a differentiated principle deriving from inter-nation equity into this new Pillar Two rule designed to regulate tax competition globally. This proposal requires that the emerging rule be disenabled in certain circumstances to enable LICs to choose whether to apply the rule without being worse off. The article’s proposal seeks to allow LICs room for effective tax competition needed to attain sustainable development goals.
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| OP 2141/2024/10 Intertax | OP 2141/2024/10-1 Building the gateway | OP 2141/2024/10-2 The Pillar 2 Directive and the qualified domestic (minimum) top-up tax puzzle | OP 2141/2024/10-3 Inter-nation equity and the regulation of tax competition via the global minimum tax rule | OP 2141/2024/10-4 Five years of digital services taxes in Europe | OP 2141/2024/10-5 30 years of the Economic European Area | OP 2141/2024/11 Intertax |
This article submits that the Pillar Two minimum tax rule – the Global Anti-Base Erosion (GloBE) Rules encompassing the income inclusion rule (IIR), undertaxed payment/profit rule (UTPR), and qualified domestic minimum top-up tax (QDMTT) – should incorporate inter-nation equity to prevent exacerbating global inequality and poverty. Pillar Two intensifies these for at least two reasons: (1) it restricts the positive redistributive effects of tax competition on an inefficiently asymmetrical global society, and (2) it encourages tax competition more suited for high-income countries (HICs) and less suited for those that are low-income countries (LICs). There is latitude to incorporate a differentiated principle deriving from inter-nation equity into this new Pillar Two rule designed to regulate tax competition globally. This proposal requires that the emerging rule be disenabled in certain circumstances to enable LICs to choose whether to apply the rule without being worse off. The article’s proposal seeks to allow LICs room for effective tax competition needed to attain sustainable development goals.
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