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The treatment of tax incentives under Pillar Two

Author

Listed:
  • Belisa Ferreira Liotti
  • Joy Waruguru Ndubai
  • Ruth Wamuyu
  • Ivan Lazarov
  • Jeffrey Owens

Abstract

This paper analyses the potential impact of the minimum tax envisaged under the OECD Pillar Two on several common corporate tax incentives. It reaches the conclusion that while the impact is expected to be low to moderate for some common incentives, such as participation exemption regimes and accelerated depreciations, it might be significant for direct cuts from the tax bill, which include tax holidays, intellectual property (IP) box regimes and special economic zones (SEZs). Hence, the response by policymakers must be informed by the specific interaction between the corporate tax incentives under their respective systems and the upcoming international standards on the minimum level of taxation

Suggested Citation

  • Belisa Ferreira Liotti & Joy Waruguru Ndubai & Ruth Wamuyu & Ivan Lazarov & Jeffrey Owens, . "The treatment of tax incentives under Pillar Two," UNCTAD Transnational Corporations Journal, United Nations Conference on Trade and Development.
    • Handle: RePEc:unc:tncjou:89
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    File URL: https://unctad.org/system/files/official-document/diaeia2022d3a2_en.pdf
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    Cited by:

    1. Bührle, Anna Theresa & Nicolay, Katharina & Spengel, Christoph & Wickel, Sophia, 2023. "From corporate tax competition to global cooperation? Trends, prospects and effects on German family businesses," ZEW Discussion Papers 23-027, ZEW - Leibniz Centre for European Economic Research.
    2. Gundert, Hannah & Nicolay, Katharina & Steinbrenner, Daniela & Wickel, Sophia, 2023. "The tax attractiveness of EU locations for corporate investments: A stocktaking of past developments and recent reforms," ZEW Discussion Papers 23-066, ZEW - Leibniz Centre for European Economic Research.

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