GloBE rules to be enforced from January 2024 despite major challenges

The OECD framework Two-Pillar Solution the global corporate minimum tax rate of 15% (Model GloBE Rules), imposed on large multinational companies with annual revenues of $790 million (€750 million) a proposal drafted by the OECD alongside G-20, whose negotiations from 2013 to 2022, are expected to start implementing it from the fiscal year starting on 1 January 2024.

However, the global corporate minimum tax is still far from being implemented (only about 55 countries have done so); the United States and China, the world’s main economies, have not yet approved it, and, in developing countries, none of them have approved it. has implemented, nor is there any knowledge of any project that contemplates it at the moment.

In Latin America, it has not been implemented by any country and Brazil, which is one of the most developed major economies in the region, has requested, together with China and India, to advance the work of the United Nations (resolution UN mandate to develop a framework convention on international tax co-operation) for an alternative tax proposal. The same situation can be seen on the African continent.

The dominant position of developing countries is that the global tax harms foreign direct investments in the region by multinational groups and does not represent a true increase in revenue, in addition to preventing the application of tax holidays or breaks, free zones, low corporate tax rates and other fiscal incentives, used to attract foreign investments or also, the possibility of applying digital taxes.

In Europe, for its part, even though the European Commission has adhered to the GLOBE Council Directive (EU) 2022/2523 of 14 December 2022. and has approved the creation of a 15% tax on companies with income exceeding 750 million, establishing a deadline until 31 December 2023 for member countries to “bring into force the laws, regulations and administrative provisions necessary to comply with this Directive”, there are still many European countries – approximately half – including Western countries European (the Iberian Peninsula, Spain and Portugal), Greece and the countries of Eastern Europe, are still far from dictating the measures to transpose this directive into their internal national legislation.

All these facts lead to think that the transition period towards the GloBE is going to be quite extensive.

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