Schjelderup, Guttorm; Stähler, Frank - 2023
This paper shows that the OECD inclusive framework of Pillar Two fails to implement the claimed 15% minimum corporate …-based Income Exclusion of Pillar Two allows to tax-deduct payroll costs and user costs of intangible assets twice from the tax base … of the top-up tax. Employing a standard multinational firm model, we show that Pillar Two changes the employment …