Abstract:
Globalization and digitalization have profoundly changed and shaped the international tax law
and the rapid changes of the last decades have often jeopardized its effectiveness and
competitiveness.
Double non-taxation has become an increasingly topical issue since the beginning of the 21st
century: large multinational enterprises have exploited loopholes in the corporate tax regimes
in order to lower their tax burden, while undermining fair competition between countries.
Over the years, international organizations updated the models and conventions in order to
adjust the international tax regime to this new scenario. To date, more than 140 countries, as
part of the OECD/G20 Inclusive Framework on BEPS Project, agreed on adopting the Global
Anti-Base Erosion Rules (GloBE), which consist of a two-Pillar scheme aimed at ensuring
that multinational enterprises are subject to a minimum tax rate in each country they operate
in.
This work aims at outlining a broad picture on the topic of corporate taxation, with the view
to understand if the new “Global Minimum Tax” may also represent a solution to the old issue
of double non-taxation and to the harmful tax competition between jurisdictions.
