Abstract

Under an inclusive framework for tax base erosion and benefit transfer as agreed by the G20 countries and the Organization for Economic Cooperation and Development, nations are considering the adoption of a global minimum corporate income tax for taxing multinationals based upon ‘Pillar Two’ proposals that are relevant for taxation for a globalized world in a digitalized era. The basis of the two pillars approach is the re-allocation of an additional share of profit to the market jurisdictions and minimum tax. The article provides a detailed analysis of the new two-pillar program aimed at reforming international tax rules and ensuring that multinational companies ought to pay a fair share of taxes wherever they operate. This article takes India as a case study and focuses on analyzing the proposed global minimum corporate tax.

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