FAIR TAXATION UNDER THE GLOBAL ANTI-BASE EROSION RULES?

In 2021 the OECD launched the Global Minimum Company Tax to implement the Action 1 of the BEPS Project. This instrument has seen as a good mechanism to prevent company avoiding taxes at the global level and to stop existence of the harmful tax regimes worldwide, as well as a good mechanism to achieve fair taxation in the era of global digitalization. However, the broke-out of the COVID-19 pandemic and, consequently, the close of the national borders, then armed conflict between Russia and Ukraine, boost financial crisis and the crises in almost all social and industrial spheres at the global level. Such unwilling trend, between all, has influenced behavior of the companies and the initial optimism of the OECD and other international organizations that the global minimum company tax, at the very end, would end existence of the harmful tax regimes, tax avoidance and unfair taxation, dropped significantly. Therefore, at the very end of the 2022 and the beginning of the 2023, the OECD launched consultation document on tax certainty in the application of the Pillar Two of the global minimum tax known as a GloBE (Global Anti-Base Erosion) Model Rules. This paper deals with mentioned issue and actual problems that the application of the GLoBE rules is faced with.

TAX TRANSPARENCY OF THE OPERATIONS OF MULTINATIONALS IN THE ERA OF COVID-19

Multinationals (MNEs) have an important influence in business activities around the world. They not only tailor the global business models, but also have significant impact on allocation of the global income and wealth, and consequently on the lives of the people in all the countries where doing business. Bigger business - bigger risk, but also bigger income and tendency to hide it and pay less or no tax and other fees. In last few decades, MNEs created different schemes in business and tax planning with intention to avoid (legally or illegally) great part of their tax duties. Since last decade of 20th century, many international organizations have been working on different (but, interrelated) projects to prevent and/or sanction such a behavior of MNEs and make their business operations more transparent. However, COVID-19 pandemic, global locks of cross-borders and conduct of almost all types of business online, put a shadow on many MNEs' business operations and open a door to different methods of tax avoidance. This paper deals with global projects and achievements that made MNEs' operations more transparent in earlier period and difficulties national and international administrations are faced with in making MNEs' playing fair and pay taxes in states where they are making business and income, which have become larger and bigger caused with global pandemic. And, finally, achievement of the agreement on global minimum tax multinationals should pay.