Article: Revenue Effects of the Global Minimum Tax Under Pillar Two

Abstract

In October 2021, 137 countries and jurisdictions agreed to implement a major reform of the international corporate tax system, i.e., a global minimum tax of 15% on the profits of large multinational companies. This article presents simulations of the revenue effects of the global minimum tax. Two possible scenarios are considered regarding who collects the minimum tax: The country in which the headquarters are located based on the income inclusion rule (IIR) or the host country of foreign affiliates as laid out under the qualified domestic minimum top-up tax (QDMTT). The Organization for Economic Cooperation and Development’s (OECD’s) tabulated country-by-country report (CbCR) statistics are complemented with data by Tørslov, Wier, and Zucman (2020). Based on a sample of eighty-three parent countries, it is estimated that headquarters countries could collect a total revenue of EUR 179 billion globally. The EU Member States could receive EUR 67 billion from a 15% minimum top-up tax. Carve-outs, provisions that decrease the tax base for real economic activity, reduce the potential tax revenues by approximately 14% to 22% over the entire sample. Under the current agreement, the European Union can expect a total tax revenue of EUR 55 billion yearly. The analysis accentuates how the distribution of revenues varies depending on which country has the priority to collect. Under the IIR in which the headquarters country collects the top-up tax, a country receives more revenues when it hosts more headquartered multinationals. With qualified domestic top-up taxes that give the host country of the foreign affiliate the priority to collect the top-up tax, low-tax jurisdictions that have attracted affiliates of many multinationals could be among the main beneficiaries of the reform. Static estimates that take the distribution of profits and taxes paid as given, are presented. Thereafter possible behavioural effects that may affect the estimates are discussed. International taxation, tax deficit, global minimum tax