Further investigation of the Global Minimum Tax
This conference addressed important and not fully explored issues with respect to the agreement of the G20/OECD Inclusive Framework for a global minimum tax.
Measurement of, and constraints on, the tax base
What problems might be solved, or might be likely to arise, in the new dependence of the measure of GloBE income on financial accounts? What will be the role of the Arm’s Length Price in Pillar 2? How far will the Pillar 2 rules constrain the choices of source country governments – for example, how would the system react to an allowance for corporate equity (an ACE, or DEBRA, as now advocated by the European Commission), investment incentives, refundable tax credits, timing differences, or other forms of minimum taxation? What about the interaction of Pillar 2 with existing and possible new CFC rules?
Chair: James Hines, University of Michigan
- Michelle Hanlon, MIT
- Michael Hashemi, HMRC
- Ulrike Schramm, Continental AG
- John Vella, Centre for Business Taxation, University of Oxford