2022 Volume 19 Pages 1-22
The main issues regarding international taxation shifted from the international double taxation and intetnational tax avoidance to the intetnational double non-taxation, with the result that “base erosion and profit shifting” (BEPS) is now a serious worldwide political and social problem. The OECD published BEPS Final Report in October 2015 in response to BEPS arising from the the intetnational double non-taxation by the globalisation of multinational enterprises and the digitalisation of economy. The report was adopted by the G20 Finance Ministers meeting in Novenber 2015. The OECD then established the OECD/G20 Inclusive Framework on BEPS (“BEPS Inclusive Framework”) in 2016 in order to address the tax challenges arising from the digitalisation of economy and in October 2020, it published reports on the Pillar One and Pillar Two Blueprints as a possible basis for a consensus solution to the issues on BEPS. “Pillar One” focused on nexus and profit allocation applicable to business profits in order to ensure a level playing field among all jurisdictions and realise a fairer and more efficient allocation of taxing rights. In “Pillar Two”, the global introduction of a minimum corporate tax rate was proposed in order to ensure that all large internationally operating businesses pay at least a minimum level of tax.
In this article, the contents and the characteristics of “Pillar Two” in the reports on the pillar blueprints endorsed in October 2020 by the BEPS Inclusive Framework, as well as the final agreement by G20 in October 2021 are analysed, and the international taxation issues (BEPS) are explored theoretically.
