The Potential Trade Law Implications of the Implementation or Non-Implementation of the Global Minimum Tax

Journal
Dwi Nugroho, A.; Brotoatmodjo, M.A.
International; OECD
Bulletin for International Taxation 2025 (Volume 79), No. 4
Price USD 45

The global minimum tax framework has enabled jurisdictions to apply the Qualified Domestic Top-up Tax (QDMTT). Its application may lead to potential trade barriers, as it excludes domestic entities that are not members of an MNE. This condition potentially creates violations against the most-favoured nation and national treatment principles.