Global Minimum Tax and National Interests:Strategic Incentives for Pillar Two Adoption
This Article systematically analyzes strategic incentives for adopting or retaining Pillar Two's three main components:the Income Inclusion Rule(ⅡR),the Qualified Domestic Minimum Top-Up Tax(QDMT),and the Undertaxed Profits Rule(UTPR).It finds that such incentives are surprisingly weak for national-income-maximi-zing governments.The Article's findings suggest that if countries are motivated by national self-interest,then even after many adopt Pillar Two,the regime may still unravel.Indeed,the fact that Pillar Two contemplates very sub-stantial wealth transfers among countries makes its"incentive compatibility"highly unlikely.The Article also shows the extraterritorial and non-extraterritorial interpretations of the UTPR raise distinct normative questions a-bout international law;normative debates about the UTPR should therefore pay closer attention to the UTPR's pos-itive features.
Global Minimum TaxPillar TwoInternational TaxationⅡRUTPRQDMT
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