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Research on the Two-Pillar Solution and Its Implication
- 1 The Australian National University
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Abstract
With the rapid development of economic globalization and digitalization, new business models are activating the world economy while exacerbating the remaining problems of base erosion and profit shifting (BEPS). In the face of intensifying international tax avoidance, The Organisation for Economic Co-operation and Development (OECD) has announced its Two-pillar solution to the international community, proposing a global minimum tax regime, which is effectively a coordination of global anti-tax avoidance measures. At present, Pillar 2 has come into effect, and Pillar 1 has also been opened for signature, marking the implementation stage of the two-pillar solution. In this paper, the two-pillar solution is the main research object. Firstly, from the perspective of large-scale tax avoidance by multinational corporations, this paper systematically analyzes the historical background of the introduction of the two-pillar solution of the OECD. After a detailed analysis of the provisions of the two-pillar solution, the existing institutional deficiencies and obstacles to its implementation are proposed. Finally, in response to the issues raised, practical recommendations are made that the elements of the two-pillar solution should aim to achieve general equity, balance the interests of developing countries and be in harmony with existing international tax policies. The governments should also optimize the structure of tax incentives.
Keywords
Tax avoidance, OECD, Two-pillar solution
[1]. Institute on Taxation and Economic Policy. (2017) Fact Sheet: Apple and Tax Avoidance.
[2]. OECD. (2013) Addressing Base Erosion and Profit Shifting, OECD Publishing.
[3]. OECD. (2021) Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy.
[4]. OECD. (2020) Tax Challenges Arising from Digitalisation: Report on Pillar One Blueprint: Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project.
[5]. Shen Tao, Lliu Qichao, Li Ruikang. (2024) A panoramic view of the taxable rules of Pillar II. International Taxation, 7,38-44.
[6]. Robert J. Misey, Jr. Michael, S. Schadewald. (2018) Practical Guide to U.S. Taxation of International Transactions (Eleventh Edition). Wolters Kluwer.
[7]. Y. Brauner. (2022) Agreement? What Agreement? OECD Statement in Perspective. Intertax, 50(1),2.
[8]. Zhu Qing, Bai Xueyuan. (2023) OECD Two-Pillar International Tax Reform Solution: Transposition and Response. International Taxation in China, 7.
[9]. Peter A. Barnes, H. David Rosenblum. (2023) Pillar 1 and Pillar 2: Pursuing perfection is a good idea, but the road ahead is difficult. International Taxation, 4,29-35.
[10]. Sol Picciotto. (2023) International Taxation of Multinational Enterprises at the Crossroads. International Taxation, 5,32-38.
Cite this article
Yuan,J. (2024). Research on the Two-Pillar Solution and Its Implication. Lecture Notes in Education Psychology and Public Media,65,68-75.
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Volume title: Proceedings of the 3rd International Conference on International Law and Legal Policy
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