Some Issues on the New Framework of International Tax Rules due to Economic Globalization and Digitalization and Their Theoretical Consistency : Focusing on Digital Taxation and Global Minimum Taxation

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  • 国際課税ルールの新たな枠組みとその理論的整合性に関する問題提起 : デジタル課税とグローバル・ミニマム課税を中心に

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Abstract

In this paper, we examine the significance and challenges associated with the implementation of new international tax rules based on two fundamental pillars: digital taxation and global minimum taxation. We discuss how this shift to new international tax rules maintains consistency with existing international tax principles. Firstly, Pillar 1 primarily addresses the situation where platform companies generate profits in market countries without physical bases by establishing the locus of economic value creation as the basis for taxation. Secondly, Pillar 2 involves creating a framework that imposes a unified minimum tax rate on Multinational Enterprises (MNEs) to prevent profit shifting to low-tax countries, thus maintaining consistency with traditional principles while addressing issues that these principles do not fully cover. Thirdly, the discussion on the cost distribution related to the two pillars is based on the relationship of benefit and ability between platform companies, including MNEs, and the market countries. This is predicated on the assumption that MNEs have the capacity to pay taxes, gaining the right to utilize infrastructure and services in market countries in return for their tax contributions, a concept based on the enjoyment of benefits. Fourthly, we demonstrate that the tax revenues derived from these two pillars offer options for investment in digital infrastructure, building a sustainable socio-economic environment, and funding for public services and social welfare in market countries.

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