Effective Tax Rate Criteria and Source Taxation under the OECD’s Pillar Two Proposals

Schoueri, L.E.; Santos, B.C. Fettermann Nogueira dos

Effective Tax Rate Criteria and Source Taxation under the OECD’s Pillar Two Proposals

Journal

Author

Schoueri, L.E.; Santos, B.C. Fettermann Nogueira dos

Country

International; OECD

Published Date

13 July 2023

Issue

Bulletin for International Taxation 2023 (Volume 77), No. 9

DOI

https://doi.org/10.59403/qqsxjs

Document

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This article aims to analyse how the effective tax rate criteria of the OECD’s Inclusive Framework Pillar Two proposal affects source taxation, particularly with regard to its effects on developing countries as Source Countries.

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Effective Tax Rate Criteria and Source Taxation under the OECD’s Pillar Two Proposals