Globalization of the
economy that is characterized by the rising integration of the markets,
digitalization of the business operations, and rise in the complexity of
cross-border corporate organizational forms has made the international taxation
of multinational businesses (MNCs) a burning question in the global economic
governance. Conventional international tax laws were structured in the light of
the concepts of residence-based and source-based taxation, assigning the
country the right to tax. Nevertheless, these principles have not worked well
in the contemporary international economy where multinational corporations are
able to conduct business in more than one jurisdiction and make profits without
a substantial physical presence.
Research results indicate
that multinational companies are transferring hundreds of billions of dollars
of profits each year to low-tax destinations which results in major loss of revenues
by governments all over the world. To these obstacles, the governments and
international bodies have come up with significant reforms to empower global
taxation. Also, the adoption of the global minimum corporate tax via Pillar Two
in the OECD framework would create minimum effective tax rate of approximately
15 percent among large multinational corporations in order to minimize
incentives to shift profits and engage in pernicious tax competition among
nations. This paper discusses the legal issues that are linked to multinational
companies taxation and the effects of the current international tax reforms
aimed at eliminating these problems. The study emphasizes the need of
international policies to work together, greater transparency, and improved regulatory
framework in an effort to provide a transparent and sustainable system of
international taxation.
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