Global Minimum Taxation and Corporate Tax Systems

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Type and Duration

PhD-Thesis, since April 2024

Coordinator

Institute for Finance

Main Research

Wealth Management

Description

The dissertation project focuses on the relationship between the Global Minimum Tax and corporate tax systems. Corporate tax systems and regulations across the world vary significantly in their underlying principles and their approach to tax. Taxes are a significant location factor for attracting and maintaining investment and, thus, for economic prosperity. Therefore, the peculiarities of a jurisdiction's tax laws and regulations create complexities and uncertainties in light of the Global Minimum Tax that challenge the competitive position of both high- and low-tax jurisdictions. The dissertation revolves around three, possibly four, research projects. The first research project aims to analyse the effectiveness of corporate tax systems in capturing substance-based 'value added' in the context of the Global Minimum Tax. The project examines the role of the tax rate differential between high- and low-tax jurisdictions, which is expected to be reduced by the Global Minimum Tax, in the incentive of a multinational group to shift profits artificially. The second research project assesses the impact of GloBE on high- and low-tax jurisdictions with diverse economic structures that provide a variety of tax incentives. As part of the planned research projects, the third project will examine the impact of the Global Minimum Tax on tax neutrality provisions. A special focus lies on the effects of the Global Minimum Tax on Allowance for Corporate Equity provisions in the context of various similar regulations in Europe, as well as the EU's ongoing efforts to reduce the corporate income tax bias towards debt financing. Both the second and the third projects rely on a model-based Effective Tax Rate methodology. The fourth project reviews and evaluates the method of implementation of the Global Minimum Tax into domestic legislation in Liechtenstein and could, if appropriate, also become part of the dissertation.