Published online by Cambridge University Press: 28 June 2025
Globalization has become a double-edged sword for countries to implement a beneficial tax policy. On one hand, there are increased opportunities for attracting foreign capital and the benefits that increased jobs and tax revenue brings to a society. However, there is also more tax competition among countries to attract foreign capital and investment. As tax competition has grown, effective corporate tax rates have continued to be cut, creating a race to the bottom. The global minimum tax proposed in Pillar Two aims to end tax competition by setting a floor for corporate tax rates with various corrective measures so that multinational enterprises’ income is taxed once in either source or residence country at a substantive tax rate. This chapter explains that Pillar Two is the first implementation of the single tax principle at the global level, breaks down the principles and policies that comprise Pillar Two, and anticipates what promise and pitfalls passage of the global minimum tax will bring. Pillar Two requires an unprecedented amount of coordination among countries for implementation, but it is reasonable to anticipate its success if it is implemented by all the G20 countries.
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