It has recently been argued in the international tax literature that the OECD Base Erosion and Profit Shifting project (BEPS) reflects and effectuates full taxation, namely an international norm that would suggest that all of a company's income should be taxed in places where it has real...

This contribution analyses the complexities and potential unintended outcomes that derive from the interaction between the GloBE rules and tax neutral regimes, namely regimes that ensure a single level of taxation at the level of the owners of an entity. Most notably, this chapter argues that...