000			01930nab a2200241 c 4500
999			_c145359 _d145359
003			ES-MaIEF
005			20220209163705.0
007			ta
008			220209t2021 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100			_949618 _aEnglisch, Joachim
245		0	_aNon-harmonized implementation of a GloBE Minimum Tax _bhow EU Member States could proceed _c Joachim Englisch
260			_c2021
500			_aResumen.
520			_aSince July 2021, more than 130 member countries of the G20/OECD Inclusive Framework (IF) have committed themselves to pursuing a ‘common approach’ on an international effective minimum tax regime. This political agreement implies that member countries who wish to implement such a tax regime have to streamline its design by modelling it after the so-called Global Anti-Base Erosion Proposal (‘GloBE’) that the IF has developed as ‘Pillar 2’ of its work program on tax challenges arising from the digitalization of the economy. This article explores how individual EU Member States could implement this agreement in conformity with EU fundamental freedoms also absent – or ahead of – harmonizing EU legislation to this effect. It is demonstrated that design alternatives to the often proposed extension of the carve-out for ‘substance-based’ activities exist and should be pursued. In particular, EU Member States could extend the minimum top-up tax approach to domestic entities of in-scope multinational enterprises (MNEs). Alternatively, they could also convert GloBE into a form of unitary minimum taxation.
650		4	_aTIPO MÍNIMO GLOBAL _967681
650		4	_aAPLICACION _927355
650		4	_aARMONIZACION FISCAL _931085
650		4	_aSEGUNDO PILAR (OCDE) _967772
650		4	_aUNION EUROPEA _948644
773	0		_9166490 _oOP 2141-B/2021/5/6 _tEC Tax Review _w(IEF)124968 _x 0928-2750 [print] _gv. 30, n. 5-6, December 2021, p. 207-219
942			_cART