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Taxation of Multinational Businesses

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Fatal flaws of OECD Pillar Two Global Minimum Tax Foundation

The Fatal Flaw of Pillar Two

Pillar Two, the international global minimum tax agreement, has a considerable chance of failing and may ultimately allow the same problems it was designed to address.

6 min read
Tax Foundation Discussion on the Harms of Retaliatory Tax and Trade Policies with Senator Blackburn

Tax Foundation Discussion on the Harms of Retaliatory Tax and Trade Policies

Historical evidence and recent studies have shown that retaliatory tax and trade proposals raise prices and reduce the quantity of goods and services available to U.S. businesses and consumers, resulting in lower incomes, reduced employment, and lower economic output.

5 min read
2017 tax reform including the Tax Cuts and Jobs Act TCJA impact of GILTI FDII and BEAT

The Impact of GILTI, FDII, and BEAT

The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA’s international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years.

30 min read
global tax agreement global tax deal OECD global minimum tax rules corporate minimum tax rules Secretariat Proposal, OECD Public Consultation Document, Unified Approach under pillar one profit shifting definition tax planning and avoidance foreign direct investment FDI global tax deal impact of global tax agreement OECD international tax proposal

The Latest on the Global Tax Agreement

The agreement represents a major change for tax competition, and many countries will be rethinking their tax policies for multinationals.

7 min read
Moore tax case of Moore vs United States consumption tax base

Why Moore v. U.S. Won’t Get Us a Consumption Tax Base

At first glance, a ruling for the plaintiffs in Moore might seem to solve some of the timing problems with the U.S. tax system. Unfortunately, upon greater inspection, such a ruling might create new timing problems. And the more rigid the ruling, the harder it would be to fix the timing problems it would create.

5 min read
Tax competition and the global minimum tax: the latest on the global tax agreement at the OECD

What’s Next for Tax Competition?

The rules of tax competition are changing with the recent agreement on a global minimum tax and other changes to tax rules around the world, but that does not mean the contest is over.

5 min read
Details and Analysis of Making 2017 Tax Reform Permanent

Details and Analysis of Making the 2017 Tax Reforms Permanent

Lawmakers will have to weigh the economic, revenue, and distributional trade-offs of extending or making permanent the various provisions of the TCJA as they decide how to approach the upcoming expirations. A commitment to growth, opportunity, and fiscal responsibility should guide the approach.

18 min read
2023 European Tax Policy Scorecard Tax Foundation Europe

2023 European Tax Policy Scorecard

The variety of approaches to taxation among European countries creates a need to evaluate these systems relative to each other. For that purpose, we have developed the European Tax Policy Scorecard—a relative comparison of European countries’ tax systems.

52 min read
CCCTB vs. BEFIT: EU Corporate Tax Base: Details & Analysis

CCCTB vs. BEFIT: How Have the Proposals Changed?

If the EU is going to harmonize its tax base, it should do so in a way that increases the efficiency and competitiveness of tax policy for the EU as a whole, and not just seek out the lowest common denominator.

5 min read

International Tax Competitiveness Index 2023

While there are many factors that affect a country’s economic performance, taxes play an important role. A well-structured tax code is easy for taxpayers to comply with and can promote economic development while raising sufficient revenue for a government’s priorities.

88 min read
Pillar One US Treasury Consultation on OECD proposal for public review input and comments

Five Takeaways from the New Pillar One Documents

The OECD recently released a trove of new documents on a draft multilateral tax treaty. The U.S. Treasury has opened a 60-day consultation period for the proposal and is requesting public review and input.

7 min read
Anti-Avoidance Policies in a Pillar Two World including CFC rules and Base erosion and Profit Shifting Pillar Two policies

Anti-Avoidance Policies in a Pillar Two World

The global minimum tax agreement known as Pillar Two is intended to curb profit shifting. However, OECD countries already have a variety of mechanisms in place that seek to prevent base erosion and profit shifting by multinational corporations.

40 min read
OECD global tax deal Pillar Two revenue estimate by country of annual and average corporate tax revenue

Select Country-Level Revenue Estimates for Pillar Two

Pillar Two implementation is underway in many jurisdictions, and many governments are aiming to get their proposals approved before the end of 2023. However, estimating Pillar Two’s impact on government revenue is proving difficult. As a result, only a few countries have publicly presented their findings.

7 min read