In view of the looming adoption of domestic minimum tax regimes under the Global Anti-Base Erosion (GloBE) as a means of ensuring that multinational enterprises pay a minimum level of tax, Noked in this paper notes the absence of guidance on several important design and policy issues concerning domestic minimum tax and analyzes the relevant rules in the OECD Model Rules and the guidance in the Commentary. He also explores several questions that the OECD and the GloBE Implementation Framework should consider regarding the design of domestic minimum taxes and related issues such as collateral benefits.
Click here to read. Subscription required.
About the author