Article: Some EU and Tax Treaty Law Considerations on the Draft EU Directive on Global Minimum Taxation for Multinationals in the Union

Abstract

In this article the author examines whether the draft EU Directive on Global Minimum Taxation for Multinationals complies with primary Union and whether the GloBE Model rules comply with the commitments undertaken by jurisdictions under their bilateral tax treaties that follow the OECD Model. Suggestions are also made on how the prevention and resolution of disputes under the Globe Model rules can be improved. Global Minimum Taxation for Multinationals, GloBE Model Rules, draft EU Directive on Global Minimum Taxation for Multinationals, Compliance with primary Union law, Compliance with the OECD Model Tax Convention, Dispute Prevention and Resolution.