000			01835nab a2200193 c 4500
999			_c149857 _d149857
003			ES-MaIEF
005			20241003172537.0
007			ta
008			241003s2024 us ||||| |||| 00| 0 eng d
040			_aES-MaIEF _beng _cES-MaIEF
100			_965605 _aHerzfeld, Mindy
245	1	4	_aThe next phase of Pillar 2 implementation _bcreative competition _c by Mindy Herzfeld
260			_c2024
520			_aAdvocates for a global corporate minimum tax promised that it would bring international tax harmonization and reduce — if not eliminate — tax competition. As countries consider how to revise their domestic rules in light of the OECD global anti-base-erosion (GLOBE) agreement and the EU minimum tax directive, it’s becoming increasingly clear that the inclusive framework agreement on pillar 2 will result in neither of those outcomes. The latest iteration of pillar 2 implementation reveals the variability and creativity of countries’ responses as they seek to ensure that they can continue to attract both domestic and foreign investment and that formal adoption of the GLOBE rules won’t result in a loss of business investment, revenue, or jobs. The OECD, in drafting the GLOBE model rules and accompanying guidance, already anticipated that countries might try to evade requirements that countries subject corporate profits to a minimum level of tax. It warned that aggressive responses might violate the terms of the agreement. Countries must now walk a fine line between adhering to the formalities of what they agreed to and maximizing their attractiveness to business investment.
650		4	_967772 _aSEGUNDO PILAR (OCDE)
650		4	_942888 _aESTADOS UNIDOS
773	0		_9172359 _oOP 138-Bis/2024/114/12 _tTax Notes International _w(IEF)124525 _x 1048-3306 _g v. 114, n. 12, June 12 2024; p. 1727-1732
942			_cART