Schjelderup, Guttorm; Stähler, Frank - 2023
This paper shows that the OECD inclusive framework of Pillar Two fails to implement the claimed 15% minimum corporate … tax for subsidiaries of multinational corporations. The reason is that the Substance-based Income Exclusion of Pillar Two … standard multinational firm model, we show that Pillar Two dampens tax motivated transfer pricing, but changes the employment …