The Impact of the Global Minimum Tax on Tax Competition
This article examines the impact of the Pillar Two Global Anti-Base Erosion (GloBE) Rules on tax competition. It sets out and explores three main conclusions on the GloBE Rules’ impact on tax competition. First, the GloBE Rules set a floor on tax paid on profit by multinationals equal to 15% of “Excess Profit”. They also set a floor on competition among “source” countries. Second, the GloBE Rules may provide some countries with an incentive to raise revenues through a qualified domestic minimum top up tax rather than a corporation tax. Third, countries can compete below the floor by offering grants and “Qualified Refundable Tax Credits”. The article proposes an alternative design for the top-up tax calculation that may have been preferable. Overall, it concludes that the impact of the GloBE Rules on tax competition may be less straightforward and significant than may have been expected. The rules also create incentives that are not clearly desirable from a policy perspective.