Multilateral Cooperation in Tax Law

1. Introduction

The global anti-base erosion (GloBE) rules are, next to those of Pillar One, the most substantial changes introduced in the field of direct taxes in a century as they promise to drive consensus toward the implementation of policies at the global level that avoid harmful competition.

Scepticism has been raised by several stakeholders regarding the nature of the framework under which GloBE has evolved from being driven by the OECD core members into being supported by the Inclusive Framework on BEPS. In particular, the question often arises on whether there are benefits to be perceived by the IF members considering that most MNEs have their ultimate parent entities (UPEs) in OECD member economies or if their support results from being compelled by OECD members to accept the terms proposed.

As such, throughout this document, the author evaluates whether the GloBE represents a victory to multilateralism from the different angles of creation of the rules, their outcome, and also their success.

The first part (section 2) of this book chapter focusses on giving a brief introduction of the GloBE rules to the extent that is relevant for answering the research question.

On the basi...