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The GloBE Income Inclusion Rule and Its Global Character: Complexities Underlying Its Fully Effective Application

The GloBE Income Inclusion Rule and Its Global Character: Complexities Underlying Its Fully... This 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. http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png EC Tax Review Kluwer Law International

The GloBE Income Inclusion Rule and Its Global Character: Complexities Underlying Its Fully Effective Application

EC Tax Review , Volume 30 (6): 16 – Dec 1, 2021

The GloBE Income Inclusion Rule and Its Global Character: Complexities Underlying Its Fully Effective Application

ec Article TAX The GloBE Income Inclusion Rule and Its Global REVIEW Character: Complexities Underlying Its Fully 2021–5&6 Effective Application Carla De Pietro This 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. Keywords: Global Anti-Base Erosion (GloBE) project, Pillar Two, Income Inclusion Rule, BEPS, CFC legislation, Abuse, OECD/G20 Inclusive Framework, Saving Clause. Very importantly, 136 countries of the OECD/G20 1INTRODUCTION Inclusive Framework on the 8 October 2021 have found In May 2019 the OECD/G20 Inclusive Framework an agreement on the GloBE income inclusion rule, agreed on a Programme of Work focusing on two substantially based on the design of the rule as deli- Pillars. Pillar One deals with the allocation of taxing neated in the Report on Pillar Two Blueprint. rights between different tax jurisdictions with regard to The agreement is based on a so-called ‘common the profits of the largest multinational enterprises approach’, implying that: (MNEs). Pillar Two has – more generally – the objective of addressing ‘remaining BEPS issues’. Pillar IF...
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Publisher
Kluwer Law International
Copyright
Copyright © 2021 Kluwer Law International BV, The Netherlands
ISSN
0928-2750
Publisher site
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Abstract

This 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.

Journal

EC Tax ReviewKluwer Law International

Published: Dec 1, 2021

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