Squire Patton Boggs’ Jeff VanderWolk, addresses the global anti-base-erosion (GLOBE) rules, which provide for a 15 percent global minimum tax on the profits of large multinational enterprises.
Assuming that the plan is not derailed in some way in the coming months — and given the EU’s track record of failing to implement proposals for harmonized direct tax laws, derailment must be acknowledged as a possibility — the GLOBE rules will apply not only to EU-parented multinational groups but also to MNEs with non-EU parent companies. Moreover, the rules will apply not only to profits arising from EU operations but also to profits derived from non-EU countries. It’s worth considering, at this stage, how the new rules might play out in practice.
*This article was first published in Tax Notes on January 2, 2023.