Monday, 19 May 2025

A Global Minimum Tax Framework: Tackling Digitalisation and Base Erosion

 The rapid digitalisation and globalisation of the economy have created complex challenges for international tax systems. In response, the OECD/G20 Inclusive Framework on BEPS (Base Erosion and Profit Shifting) has developed the Global Anti-Base Erosion (GloBE) Model Rules—a coordinated approach aimed at ensuring multinational enterprises (MNEs) pay a fair share of tax, regardless of where they operate.

 

At the heart of the GloBE Rules are two key mechanisms: the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR). These apply a Top-up Tax to ensure that MNEs pay at least a minimum level of tax (15%) on income earned in each jurisdiction. Rather than acting as traditional corporate income taxes, these rules work more like an international alternative minimum tax.

 

The rules apply to MNEs with consolidated revenues of at least EUR 750 million and are designed to be implemented consistently across jurisdictions under a common approach, promoting transparency and preventing double taxation.

 

Key elements of the framework include:

  • Scope and Thresholds: Only large MNEs with global operations are covered. Smaller or purely domestic groups are excluded.
  • Income and Tax Computation: GloBE income is derived from financial statements, adjusted for tax differences. Effective Tax Rates (ETRs) are calculated on a jurisdictional basis.
  • Currency and Compliance: Rules account for currency fluctuations and allow for transitional and administrative simplifications through safe harbours and coordination mechanisms.
  • Transition and Implementation: Jurisdictions are encouraged to align their domestic laws with the model rules to ensure global coherence.

 

This initiative reflects a significant step toward global tax fairness, curbing the long-standing issue of profit shifting to low-tax jurisdictions and modernising tax systems for the digital age.

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