The European Commission recently implemented the minimum tax directive (Pillar Two) to ensure that corporate profits … equity-financed companies. In countries with a combined profit tax rate below 15%, Pillar Two increases the effective average … tax burden. The simulation of the interaction of both regulations shows that the effect of Pillar Two dominates that of …

The European Commission recently implemented the minimum tax directive (Pillar Two) to ensure that corporate profits … equity-financed companies. In countries with a combined profit tax rate below 15%, Pillar Two increases the effective average … tax burden. The simulation of the interaction of both regulations shows that the effect of Pillar Two dominates that of …

This paper shows that the OECD inclusive framework of Pillar Two fails to implement the claimed 15% minimum corporate … tax for subsidiaries of multinational corporations. The reason is that the Substance-based Income Exclusion of Pillar Two … standard multinational firm model, we show that Pillar Two dampens tax motivated transfer pricing, but changes the employment …

I present a simplification safe harbour based on tax administrative guidance for Pillar Two, the global minimum tax …

This paper shows that the OECD inclusive framework of Pillar Two fails to implement the claimed 15% minimum corporate …-based Income Exclusion of Pillar Two allows to tax-deduct payroll costs and user costs of intangible assets twice from the tax base … of the top-up tax. Employing a standard multinational firm model, we show that Pillar Two changes the employment …

This paper shows that OECD’s Pillar Two may increase employment and investment in low-tax countries due to the … corporate tax for low-taxed subsidiaries is not achieved if the SBIE is positive. We show that Pillar Two dampens tax …