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What’s The Problem That Prompted Pillar 2 And Is There A Better Solution?

J. Clifton Fleming (BYU; Google Scholar), Robert J. Peroni (Texas) & Stephen E. Shay (Boston College; Google Scholar), What's the Problem That Prompted Pillar 2 and Is There a Better Solution?:

This paper explains the origin of tax competition, notes the hostility of developed countries towards tax competition, traces the long-running efforts to limit tax competition, explains how Pillar 2 attacks tax competition, and argues that although Pillar 2 is a step in the right direction, the better approach would be for countries that host MNEs to adopt worldwide taxation, without deferral, at their respective regular corporate rates.

Conclusion
Pillar 2 partially mitigates the evils of tax competition, which is a significant step in the right direction. Nevertheless, it leaves substantial room for continuing tax competition and imposes substantial transition and complexity costs. A far better approach would be for countries that are hosts to MNEs to adopt expanded worldwide taxation, without deferral, at their respective regular corporate rates.


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