{"title":"Pillar Two’s Built-In Escape Hatch","authors":"Lilian V. Faulhaber","doi":"10.1086/723200","DOIUrl":null,"url":null,"abstract":"This article focuses on Pillar Two’s substance-based income exclusion and illustrates how it is the result of three separate international tax developments that have taken place over the past 15 years. This article argues that by allowing countries to include this exclusion in their minimum taxes, policy makers and politicians have built an escape hatch into Pillar Two that would allow certain jurisdictions to keep their tax rates low, despite headlines proclaiming the end of tax competition.","PeriodicalId":18983,"journal":{"name":"National Tax Journal","volume":"76 1","pages":"167 - 192"},"PeriodicalIF":1.8000,"publicationDate":"2023-02-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"2","resultStr":null,"platform":"Semanticscholar","paperid":null,"PeriodicalName":"National Tax Journal","FirstCategoryId":"96","ListUrlMain":"https://doi.org/10.1086/723200","RegionNum":3,"RegionCategory":"经济学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"Q2","JCRName":"BUSINESS, FINANCE","Score":null,"Total":0}
引用次数: 2
Abstract
This article focuses on Pillar Two’s substance-based income exclusion and illustrates how it is the result of three separate international tax developments that have taken place over the past 15 years. This article argues that by allowing countries to include this exclusion in their minimum taxes, policy makers and politicians have built an escape hatch into Pillar Two that would allow certain jurisdictions to keep their tax rates low, despite headlines proclaiming the end of tax competition.
期刊介绍:
The goal of the National Tax Journal (NTJ) is to encourage and disseminate high quality original research on governmental tax and expenditure policies. Articles published in the regular March, June and September issues of the journal, as well as articles accepted for publication in special issues of the journal, are subject to professional peer review and include economic, theoretical, and empirical analyses of tax and expenditure issues with an emphasis on policy implications. The NTJ has been published quarterly since 1948 under the auspices of the National Tax Association (NTA). Most issues include an NTJ Forum, which consists of invited papers by leading scholars that examine in depth a single current tax or expenditure policy issue. The December issue is devoted to publishing papers presented at the NTA’s annual Spring Symposium; the articles in the December issue generally are not subject to peer review.