The Impact of Pillar Two on In-Scope Taxpayers and Their Responses  

作　　者：Christian Kaeser 

机构地区：[1]Federation of Industries(BDI)Tax Commission [2]Siemens AG

出　　处：《Belt and Road Initiative Tax Journal》2024年第2期73-80,共8页“一带一路”税收(英文)

摘　　要：The OECD's Pillar Two initiative aims to establish a global minimumtax rate of 15% to prevent a"race to the bottom" in corporate taxation. The GIoBERules, which include the Income Inclusion Rule (IR) and the Undertaxed PaymentsRule (UTPR), introduce significant complexity for both taxpayers and tax administra-tions. Taxpayers must invest in new processes and systems to comply with the rules,which results in higher compliance costs for taxpayers and increased administrativeburdens for tax authorities. The impact of the Top-Up Tax on the cash and profit posi-tions of in-scope taxpayers varies depending on factors such as the jurisdictional mixof the MNE and the specific tax benefits available in different jurisdictions. While theTop Up Tax generally leads to a higher effective tax burden, some jurisdictions haveenacted legislation to mitigate its impact, potentially resulting in tax benefits for cer-tain MNEs.

关 键 词：GloBE Rules Pillar Two Level playing field Complexity 

分 类 号：R73[医药卫生—肿瘤]