The study analyses how the 2008 Financial Crisis and 2020 COVID-19 pandemic catalysed reform through G-20 and OECD initiatives, resulting in a two-pillar framework with conditional mismatch rules and a 15% minimum Effective Corporate Tax Rate applied country-by-country.
This book examines the transformative changes in international corporate taxation from 2008 to 2021, culminating in the landmark October 2021 agreement that fundamentally altered multinational business taxation.
The study analyses how the 2008 Financial Crisis and 2020 COVID-19 pandemic catalysed reform through G-20 and OECD initiatives, resulting in a two-pillar framework with conditional mismatch rules and a 15% minimum Effective Corporate Tax Rate applied country-by-country.
Through empirical, comparative, and meta-historical analysis, the author reveals the decisive influence of the Transnational Tax Policy Community (TTPC) as agenda-setter, adviser, and gatekeeper. Despite the TTPC's significant role, the research demonstrates that domestic politics substantially impact implementation and enforcement outcomes.
The work introduces a Dynamic Model of Corporate Tax Governance that not only explains recent revolutionary changes but also predicts future developments in global tax governance, illuminating the ongoing tension between multilateral cooperation and state sovereignty in international taxation.
Arvustused
This book is an outstanding study of how the remarkable 2021 agreement on the global corporate tax was reached and signed by over 140 countries. It should be read by anyone who is interested in the possibility of reaching multilateral solutions to global problems, not just tax experts.
- Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law at the University of Michigan
Motalas book demonstrates how systemic shocks, expert networks anchored in the OECD, and distributional conflicts among States combined to alter the foundations of international corporate taxation. The analysis advances a dynamic model of global corporate tax governance that explains both the evolutionary adjustments of the past decade and the potentially revolutionary character of the 2021 agreement. This model provides a coherent account of how crises trigger delegation to technical experts, how transnational epistemic communities construct new norms, and how bargaining among major powers and domestic political constraints determine the scope of implementation. This monograph stands out for offering not merely a historical record but an explanatory framework that will inform future scholarship on international economic law and multilateral governance.
-Julien Chaisse, Professor & RGC Senior Research Fellow, School of Law, City University of Hong Kong
The 2021 Agreement on Global Corporate Tax was unambiguously a milestone in the ongoing fight against tax havens and all ensuing negative external effects. The author has managed to put together an authoritative account of the workings of this remarkable achievement, the process that led to it, and its consequences. It is a must read volume for academics and practitioners alike.
- Petros C Mavroidis, Edwin B. Parker, Professor of Foreign & Comparative Law, Columbia Law School
Acknowledgments Commonly Used Abbreviations Introduction
Chapter 1: The
GCTR, Theories, and the Proposed Dynamic Model
Chapter 2: The Creation of the
International Tax Regime, 1920-1963
Chapter 3: The Tax Challenges of
Globalization and the Changing Digital Economy, 1963-2000
Chapter 4: The
Evolution of the GCTR, 2008-2021
Chapter 5: Causes of Change in the GCTR,
2008 2021
Michael F. Motala, JD, PhD, is an assistant professor of Law and Political Science at the University of Tulsa College of Law who teaches advanced contracts, securities, taxation, and corporate law, he is an Instructor teaching Federal Income Taxation at Osgoode Hall Law School, York University's Professional Development Program, and serves as the Director, Taxation for the G20 Research Group and the G7 Research Group at the University of Torontos Munk School of Global Affairs. Michaels primary expertise is in the global governance of international corporate taxation and its intersection with international economic law, and he has taught, conducted advanced research, and studied in the United States, Canada, the United Kingdom, Switzerland and France.
