The OECD GloBE proposal - a decisive step towards uniform global minimum taxation?

Pillar Two of the OECD's two-pillar-approach to solve the tax challenges arising from digitalization provides for the introduction of global minimum taxation of large multinational entities. This is the largest project to date to reform and align international taxation. This thesis explains and analyzes the proposed rules (based on the Blueprint published in October 2020) aimed at achieving global minimum taxation. The aim of the work is also to evaluate the effectiveness of this so-called GloBE proposal and to identify possible weaknesses and potential for improvement of these rules.

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Pillar Two of the OECD's two-pillar-approach to solve the tax challenges arising from digitalization provides for the introduction of global minimum taxation of large multinational entities. This is the largest project to date to reform and align international taxation. This thesis explains and analyzes the proposed rules (based on the Blueprint published in October 2020) aimed at achieving global minimum taxation. The aim of the work is also to evaluate the effectiveness of this so-called GloBE proposal and to identify possible weaknesses and potential for improvement of these rules.