000			01711nab a2200229 c 4500
999			_c145360 _d145360
003			ES-MaIEF
005			20220209164406.0
007			ta
008			220209t2021 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100			_962776 _aDe Pietro, Carla
245		4	_aThe GloBE income inclusion rule and its global character _bcomplexities underlying Its fully effective application _c Carla De Pietro
260			_c2021
500			_aResumen.
520			_aThis article focuses on the complex challenges affecting the relationship between different tax systems (national, international and EU) within a context, like the current GloBE project, which is looking for appropriate tax measures applying on a global scale. In fact, the need of developing tax measures with a global character requires specific attention to be given to issues concerning the effectiveness of these measures in light of the relationship between the relevant tax systems. More specifically, within the framework of this article, the analysis aimed at evaluating the possibilities of guaranteeing a fully effective application of the GloBE income inclusion rule has been conducted on the basis of two crucial factors, i.e. (1) the compliance of the income inclusion rule with international tax treaty law and with EU tax law, and (2) the coordination between international tax treaty law and EU tax law.
650		4	_aTIPO MÍNIMO GLOBAL _967681
650		4	_aAPLICACION _927355
650		4	_aARMONIZACION FISCAL _931085
650		4	_aSEGUNDO PILAR (OCDE) _967772
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. 220-235
942			_cART