The Global Minimum Tax | Selected Issues on Pillar Two

S. 2421. Prologue

This master thesis aims to provide comprehensive insights into the territorial allocation of constituent entities (CEs). The territorial allocation of CEs is a part of the broader set of model rules promulgated by the OECD/G20 countries and monitored by the Inclusive Framework implementing Pillar Two.^, The international consensus established in the Pillar Two Model Rules/Global Anti-Base Erosion (GloBE) Model Rules has recently found a basis in the legal order of the European Union (EU) and will therefore soon become important for tax departments of multinational enterprises (MNEs) worldwide. In other words, Pillar Two is no longer a purely theoretical, widely debated brain teaser for tax experts but an inevitable reality for MNEs.

The research design shaping this contribution is descriptive complemented by a normative component. Hence, a literature review, i.e. a research method that showcases the ability to gather existing knowledge and insights on a specific topic, will be the research method used by this thesis.

S. 243In what follows, this contribution will first focus on the importance of the territorial allocation of CEs. Thereby stating that the allocation of income earn...