Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh,...

This paper characterizes profit shifting behavior across the size distribution of multinational enterprises (MNEs) to evaluate the targeting of the recently introduced Global Minimum Tax (GMT). Using German microeconomic administrative data with no reporting gaps for tax havens, we first...

This paper characterizes profit shifting behavior across the size distribution of multinational enterprises (MNEs) to evaluate the targeting of the recently introduced Global Minimum Tax (GMT). Using German microeconomic administrative data with no reporting gaps for tax havens, we first...

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh,...

This study examines the compliance costs of OECD Pillar Two, i.e., the "Global Minimum Tax," for multinational enterprises headquartered in the European Union. Collecting data from chief financial officers and heads of finance or tax departments, we estimate compliance cost determinants and...

We assess the welfare implications of the Global Minimum Tax (GMT) on corporate income in a multi-country macroeconomic model. The objectives of the GMT are to mitigate harmful tax competition and to curb wasteful profit shifting. The theoretical literature suggests that the welfare effects of...

This study examines the compliance costs of OECD Pillar Two, i.e., the “Global Minimum Tax,” for multinational enterprises headquartered in the European Union. Collecting data from chief financial officers and heads of finance or tax departments, we estimate compliance cost determinants and...

By focusing exclusively on large multinational groups, the global minimum tax (GMT) aims to target most of the world's profit shifting while keeping aggregate compliance costs at an acceptable level. This policy brief presents new evidence on profit shifting behavior across the size distribution...

We study the effects that the introduction of the Global Minimum Tax (GMT) has from the perspective of developing countries. Our model features two asymmetric host countries for FDI that compete with each other for the location of multinational firms, and simultaneously fight profit shifting to...

The purpose of this paper is to analyze the global minimum tax of 15% for international corporations, the fiscal impact of this policy which is already in force internationally as of January 1, 2025, as well as the determinants of corporate tax revenues, with a particular focus on the Western...

We develop a methodology to decompose the tax revenue impact of the global minimum tax introduced in 2024 into several components and quantify its potential impact on profit shifting. We apply it to 34 thousand multinational-country observations from tax returns, financial statements and...

The Global Minimum Tax (GMT) is applied only to firms above a certain size threshold, permitting countries to set differential tax rates for small and large firms. We analyse tax competition between a tax haven and a non-haven country for heterogeneous multinationals to evaluate the effects of...

This chapter provides a description of one of the key anti-tax-avoidance rules to combat profit shifting by multinational corporations, so called Controlled Foreign Corporation (CFC) rules that directly target income in low-tax countries. We explain some key institutional features of CFC...

The European Commission recently implemented the minimum tax directive (Pillar Two) to ensure that corporate profits are at least taxed at 15%. At the same time, it proposed a legislative initiative aimed at reducing the tax-induced distortions between debt and equity financing (debt-equity bias...

This study assesses the impact of the Global Minimum Tax (GMT) on the attraction of foreign direct investment (FDI) in Vietnam. The authors rely on the analytical framework of UNCTAD (2022) and descriptive statistical methods to analyze and evaluate the impact of GMT on FDI attraction. The...

This chapter provides a description of one of the key anti-tax-avoidance rules to combat profit shifting by multinational corporations, so called Controlled Foreign Corporation (CFC) rules that directly target income in low-tax countries. We explain some key institutional features of CFC...

We develop a methodology to decompose the tax revenue impact of the global minimum tax introduced in 2024 into several components and quantify its potential impact on profit shifting. We apply it to 34 thousand multinational-country observations from tax returns, financial statements and...

The European Commission recently implemented the minimum tax directive (Pillar Two) to ensure that corporate profits are at least taxed at 15%. At the same time, it proposed a legislative initiative aimed at reducing the tax-induced distortions between debt and equity financing (debt-equity bias...

The Global Minimum Tax (GMT) is applied only to firms above a certain size threshold, permitting countries to set differential tax rates for small and large firms. We analyse tax competition between a tax haven and a non-haven country for heterogeneous multinationals to evaluate the effects of...

Die Implementierung der globalen Mindeststeuer ist ein wichtiger Schritt zur Modernisierung des internationalen Steuerrechts. Sie hat aber auch Auswirkungen auf bestehende steuerliche Anreize, darunter die steuerliche Förderung von Forschung und Entwicklung. Diese werden von verschiedenen...

The OECD's proposal for a global minimum tax (GMT) of 15% aims for a reversal of a decline of corporate tax rates. We study the revenue effects of the GMT by focusing on strategic tax setting effects. The direct effect from less profit shifting increases revenues in high-tax countries. A...

I present a simplification safe harbour based on tax administrative guidance for Pillar Two, the global minimum tax, developed together with Cedric Döllefeld, Joachim Englisch, Simon Harst and Felix Siegel. It aims at reducing unnecessary compliance costs by avoiding effective tax rate (ETR)...

Die Forscher des ZEW Mannheim rund um Professor Christoph Spengel kommen zu folgendem Ergebnis: Der Steuerwettbewerb hat sich abgeschwächt. Bestimmte Instrumente gegen die Gewinnverlagerung wirken. Das führt aber bisher nicht zu einer Angleichung der Steuersätze auf niedrigerem Niveau.

The OECD's proposal for a global minimum tax (GMT) of 15% aims for a reversal of a decline of corporate tax rates. We study the revenue effects of the GMT by focusing on strategic tax setting effects. The direct effect from less profit shifting increases revenues in high-tax countries. A...

This paper studies how the global minimum tax shapes national tax policies and welfare in a formal model of international tax competition with heterogeneous countries. The net welfare effect is generally ambiguous from the perspective of non-havens. On the one hand, the global minimum tax raises...

The OECD's proposal for a global minimum tax (GMT) of 15% aims for a reversal of a decades-long race to the bottom of corporate tax rates driven by competition over real investments and profit shifting to low-tax jurisdictions. We study the revenue effects of the GMT by focusing on the induced...

This paper studies how the global minimum tax shapes national tax policies and welfare in a formal model of international tax competition with heterogeneous countries. The net welfare effect is generally ambiguous from the perspective of non-havens. On the one hand, the global minimum tax raises...

The OECD’s proposal for a global minimum tax (GMT) of 15% aims for a reversal of a decades-long race to the bottom of corporate tax rates driven by competition over real investments and profit shifting to low-tax jurisdictions. We study the revenue effects of the GMT by focusing on the induced...

This paper studies how the global minimum tax shapes national tax policies and welfare in a formal model of international tax competition with heterogeneous countries. The net welfare effect is generally ambiguous from the perspective of non-havens. On the one hand, the global minimum tax raises...

The paper assesses the impact of the global minimum tax (GMT) on the taxation of multinational enterprises (MNEs), based on a comprehensive dataset capturing the global activities of large MNEs. It has four key findings. First, the GMT substantially reduces the incentives to shift profits....

Die Implementierung der globalen Mindeststeuer ist ein wichtiger Schritt zur Modernisierung des internationalen Steuerrechts. Sie hat aber auch Auswirkungen auf bestehende steuerliche Anreize, darunter die steuerliche Förderung von Forschung und Entwicklung. Diese werden von verschiedenen...

Based on the agreed Pillar 1 threshold of profitability of 10% (and given that financial and extractive companies are excluded), then only 78 of the world’s 500 largest companies will be affected. If the proportion of profit above this threshold liable to Amount A is set to 20% (from the...