Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.
Key Features:
Exploration of the Pillar 2 proposal's formative developmentDetailed discussion of key concepts such as process legitimacyExamination of the Pillar 2 objectives and the reasons which led to its adoptionAssessment of the interaction between the GloBE rules and national law, European law and existing bilateral tax treatiesConsideration of the impact of the new regime on multinational businesses and the future interaction of states through tax competitionStep-by-step analysis of the complex set of GloBE model rules that have been put in place to make the minimum taxation regime effective
This authoritative book is an essential resource for legal practitioners practising in tax law, fiscal policy and commercial law. The applied nature of the text is also of great benefit to policymakers working in the taxation sphere. Scholars and students of international taxation will similarly find this to be a useful reference.
Industry Reviews
'The "Pillar Two" Global Minimum Tax is an important and timely work bringing together new essays on a topic that has engaged the international tax community over recent years. With contributions from some of the most prominent researchers on international taxation, this book tackles a rich variety of perspectives ranging from normative analysis, through the procedural and political aspects of the issue, to some important technical analyses of the mechanics of Pillar Two. This book is bound to become a key point of reference for anyone working on the subject or studying it.' -- Tsilly Dagan, University of Oxford, UK
'This engaging book, featuring contributions from European tax experts, examines Pillar Two from what seems to be every conceivable perspective. The volume's panoptic approach yields surprising insights with respect to the issues likely to emerge from the OECD's radical reformulation of the rules of international taxation.' -- David Rosenbloom, Caplin & Drysdale, US