Friday, May 6, 2022
Chris William Sanchirico (Penn; Google Scholar), Should a Global Minimum Tax Be Country-by-Country?, 175 Tax Notes Fed. 549 (Apr. 25, 2022):
In this report, Sanchirico questions the consensus view that a country-by-country approach to global minimum tax design is superior to one based on across-country averaging.
This report shows in the context of a simple game theoretic model that a global minimum tax regime that operates on a country-by-country basis is not necessarily superior to one that is based on global averaging — at least not from the perspective of the high-tax jurisdictions spearheading reform.
The model suggests that, relative to a GAM, a CbCM forces high-tax jurisdictions to choose between less revenue or deleterious rate reductions.