Schjelderup, Guttorm; Stähler, Frank - In: International Tax and Public Finance 31 (2023) 4, pp. 935-952
This paper shows that OECD’s Pillar Two may increase employment and investment in low-tax countries due to the Substance-based Income Exclusion (SBIE). The SBIE allows to tax-deduct payroll costs and user costs of tangible assets twice from the tax base of the top-up tax owed by subsidiaries...