Reflecting the global anti-base erosion from the perspective of developing countries

Abstract

Since late 2019, new discussions on the global minimum tax rate have emerged in international tax law, centered on the GloBE proposal. The central issue discussed in this paper is the plausible impact of GloBE on developing countries. Given its origin, it is assumed that the GloBE will benefit developed countries to the detriment of developing countries. In this paper, I draw on scholars‟ criticisms of similar projects like GloBE to prove that GloBE is highly critical of developing countries‟ interests as they risk losing taxing rights and revenues. I hence advise developing countries to be mindful of this and adopt GloBE rules cautiously as they reserve the sovereign right to walk out of multilateral measures in favour of unilateral measures concerning the allocation of taxing rights.