GloBE: Why a Nominal Tax Rate of More Than 15% Might Not Be Enough

Journal
Dziurdź, K.; Marchgraber, C.
International; OECD
Bulletin for International Taxation 2022 (Volume 76), No. 11
FormatPDF
USD
45

This article explains why the effective tax rate for the purposes of the Global Anti-Base Erosion (GloBE) rules may deviate from the nominal corporate income tax rate and fall below 15%, even in high-tax jurisdictions. It further addresses the (non-)application of the substance-based income exclusion in loss situations.