The Global Minimum Tax | Selected Issues on Pillar Two

1. Introduction

The advent of Pillar Two represents an unprecedented initiative in international taxation, unveiling a multifaceted project that tackles the formidable task of aligning and bridging differences among tax systems worldwide. Establishing this new paradigm poses several compliance challenges in terms of data collection, adjustments to financial accounting, and the synchronization of information from globally dispersed entities. The compliance and administrative burden on taxpayers and tax administrations emerges as a pivotal challenge for a feasible implementation of the GloBE Rules. Recognizing the need to address this challenge, the Inclusive Framework (IF) agreed on a GloBE safe harbours framework aimed at easing the initial implementation and at simplifying calculations in low-risk situS. 576ations. Despite the simplification goal, the evolution of these tools paved the way to new complexities, potentially diminishing the benefit of their adoption.

This chapter address these challenges by delving into the functioning of the GloBE safe harbours. The overarching aim is to scrutinize whether these provisions effectively fulfill their intended purpose of facilitating the imple...