Policy Note: Beyond the 2-Pillar Solution: A Case for a Global Income Tax and the Creation of the International Tax Organization - Intertax View Policy Note: Beyond the 2-Pillar Solution: A Case for a Global Income Tax and the Creation of the International Tax Organization by - Intertax Policy Note: Beyond the 2-Pillar Solution: A Case for a Global Income Tax and the Creation of the International Tax Organization 51 4

Globalization, technological advancement, and the subsequent mobility of functions, risks, and assets in business activities present tax challenges that cannot be resolved with the existing rules. The Organization for Economic Co-operation and Development (OECD) attempted to reform the international tax system through what is referred to as the two-pillar solution consisting primarily of transferring a small portion of excess profits made by the largest multinationals to market countries (Pillar 1) and establishing a minimum 15% tax to be paid mainly in the residence jurisdiction of the ultimate parent of multinational groups (Pillar 2). Some of the agreements reached in this context may serve as grounds for a more global solution that actually resolves the issues brought by globalization and technology in a simple, inclusive, and sustainable manner. This policy brief proposes replacing current nexus rules for global taxpayers with the establishment of a global income tax by using the agreements on the calculation of the effective tax rate (ETR) for Pillar 2 and building a pilot with the multinationals selected as covered by Pillar 1. Further, the article argues for creating an international tax organization (ITO) to administer this tax, departing from the approval of the Resolution for the Promotion of Inclusive and Effective International Tax Cooperation at the United Nations in November 2022. Finally, the contribution proposes a bold spending proposal aimed at effectively addressing global challenges like climate change, including a transitional regime to support countries giving up domestic revenues due to the implementation of the proposed solution.

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