000			01687nab a2200205 c 4500
999			_c146041 _d146041
003			ES-MaIEF
005			20220715133129.0
007			ta
008			220715t2022 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100			_967682 _aTandon, Suranjali
245		4	_aThe need for global minimum tax _bassessing Pillar Two reform _c Suranjali Tandon
500			_aResumen.
520			_aIn 2021 the OECD announced its proposal to introduce a global minimum tax. This article reviews the existing international tax rules to demonstrate that their inefficient design is among the key factors that have compelled developed countries to support a global minimum rate. In contrast to the previous approach where the OECD identified harmful tax practices, pillar two seeks to address tax competition. In doing so tax rates and incentives will be re-calibrated so as to ensure that a corporation pays 15% in each jurisdiction. For this the rules allow the residence countries to tax back the difference between the minimum and effective tax rate (ETR). The design of the rules indicates that developing countries will not gain tax revenues from this proposal. A more important point for developing countries to consider is that tax structures depend on regulation and structure of the economy. This article presents evidence to suggest that countries must weigh their overall economic objectives against the minimum tax.
650		4	_967772 _aSEGUNDO PILAR (OCDE)
650			_aIMPUESTO DE SOCIEDADES _945680
650		4	_967681 _aTIPO MÍNIMO GLOBAL
773	0		_9167447 _oOP 2141/2022/5 _tIntertax _w(IEF)55619 _x 0165-2826 _g v. 50, issue 5, May 2022, p. 396-413
942			_cART