Designing Domestic Minimum Taxes in Response to the Global Minimum Tax

Countries may soon adopt domestic minimum taxes in response to the global minimum tax under the Global Anti-Base Erosion (GloBE) regime. These taxes, which will have priority over the global minimum tax under GloBE, could become the primary measure of ensuring that multinational enterprises (MNEs) pay a minimum level of tax. Despite their expected importance, the GloBE Model Rules and Commentary provide little guidance on several important design and policy issues concerning domestic minimum taxes. This article analyses the relevant rules in the Model Rules and the guidance in the Commentary. It 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