Tarcisio Diniz Magalhães (Antwerp; Google Scholar) & Allison Christians (McGill; Google Scholar), The Normative Shift in Corporate Tax Policy after GloBE, 17 World Tax J. ___ (2025):
In the era of global minimum taxes, the merit of any given national corporate income tax will depend on which governments will be collecting corporate tax revenues, and at whose expense. This marks a shift in focus away from a century-old baseline assumption: before this era, the likelihood that a corporation would face income tax at all was in no way assured, but now, any given corporate income stream will likely be subject to tax by some government, somewhereif not yet in practice, presumably some time in the near future. This shift in assumption alters the terrain for normative policy analysis by centering questions that were formerly sidelined, especially respecting the impact of taxes on the international distribution of wealth among nations. This article examines the implications of this shift and shows why it leads to a clear understanding of corporate taxes as a key international wealth distribution tool.
Conclusion
Even before its full implementation, GloBE has shifted the focus of corporate tax policy from domestic incidence to the question of which government will ultimately collect the tax revenue. This article has demonstrated why this shift is critical, arguing that GloBE renders obsolete the traditional emphasis on domestic tax incidence.
Under the new assumption of global minimum taxation, the only meaningful measure of a national corporate tax is its impact on the distribution of tax revenues among the societies that could potentially collect them. The new central question is not who bears the tax burden domestically, but which state claims the right to collect tax revenues.
As demonstrated, this question is both technical and normative, involving equity, fairness and justice in global wealth distribution. By shifting focus from incidence to distribution, GloBE thus challenges the theoretical foundations and practical considerations of traditional corporate tax policy. As governments grapple with how to allocate corporate tax revenues equitably, domestic minimum taxes emerge as an indispensable component of any sensible corporate income tax system going forward. Policymakers must therefore recognize that corporate tax policy is now, at its core, a tool for managing international resource distribution. GloBE, by establishing a floor for tax competition, reorients tax policy toward how revenues are shared among countries rather than how they are generated and from which specific individuals they are extracted.
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