The OECD Public Consultation Document 'Global Anti-Base Erosion (GloBE) Proposal - Pillar Two': An Assessment

Bulletin for International Taxation, 2-2020, IBFD

1 Pages Posted: 14 Aug 2020 Last revised: 10 Nov 2022

See all articles by João Félix Pinto Nogueira

João Félix Pinto Nogueira

International Bureau of Fiscal Documentation; Law School - Catholic University of Portugal (UCP); University of Cape Town (UCT)

Pasquale Pistone

International Bureau of Fiscal Documentation (IBFD); Vienna University of Economics and Business

Betty Andrade

International Bureau of Fiscal Documentation

Alessandro Turina

International Bureau of Fiscal Documentation (IBFD)

Date Written: November 28, 2019

Abstract

This study aims to provide feedback to the OECD on its Public Consultation, launched on 8 November 2019, on the specific matters of the Global Anti-Base Erosion (GloBE) Proposal, also known as Pillar Two of the BEPS 2.0 Project, as included in the Public Consultation Document (The "Public Consultation Document on GloBE").

Some aspects of the latter document have already been the object of a Public Consultation in February 2019. Since the IBFD TFDE has not submitted comments on that specific part of the February Public Consultation, this study also considers issues deriving from that document. Nevertheless, the goal of this study is not to make a comprehensive assessment of GloBE. We will provide that once the initiative reaches its final format.

In our view, the consultation is mostly conducted on the basis of the modus operandi of the income inclusion rule. For the purposes of this study, we will use the same baseline.

The IBFD TFDE comments, as formulated herein, comprise four sections. Following the overall assessment, each section initially indicates the specific point of the Public Consultation Document on GloBE, then elaborates on the content of the main technical proposal by the IBFD TFDE, and finally includes our contribution to the Public Consultation Document on GloBE. The latter constitutes a subordinate option, which the OECD Secretariat may take into account when evaluating possible amendments to its proposal.

Keywords: Taxation, Tax law, European taxation

JEL Classification: K33, K34, F13, E62, D78, E62, F02, F23, F42, H20, H22, H23, H25, H26, H87, O19, O23, O24

Suggested Citation

Pinto Nogueira, João Félix and Pistone, Pasquale and Andrade, Betty and Turina, Alessandro, The OECD Public Consultation Document 'Global Anti-Base Erosion (GloBE) Proposal - Pillar Two': An Assessment (November 28, 2019). Bulletin for International Taxation, 2-2020, IBFD , Available at SSRN: https://ssrn.com/abstract=3644238

João Félix Pinto Nogueira (Contact Author)

International Bureau of Fiscal Documentation ( email )

Rietlandpark, 301
Amsterdam, 1019 DW
Netherlands
+31205540100 (Phone)

Law School - Catholic University of Portugal (UCP) ( email )

Lisboa
Portugal
0650446433 (Phone)
4760-164 (Fax)

HOME PAGE: http://https://fd.porto.ucp.pt/pt-pt/pessoa/joao-nogueira

University of Cape Town (UCT) ( email )

Private Bag X3
Rondebosch, Western Cape 7701
South Africa

Pasquale Pistone

International Bureau of Fiscal Documentation (IBFD) ( email )

Rietlandpark 301
Amsterdam, 1019 DW
Netherlands

Vienna University of Economics and Business ( email )

Welthandelsplatz 1
Vienna, Wien 1020
Austria

Betty Andrade

International Bureau of Fiscal Documentation ( email )

Amsterdam
Netherlands

Alessandro Turina

International Bureau of Fiscal Documentation (IBFD) ( email )

Rietlandpark 301
Amsterdam, 1019 DW
Netherlands

Do you have negative results from your research you’d like to share?

Paper statistics

Downloads
605
Abstract Views
1,340
Rank
82,000
PlumX Metrics