![handle is hein.journals/vajoillw64 and id is 1 raw text is:
ONLINE
Ending the Vicious Cycle: Understanding
Pillar Two and the Uncertain Progress
Towards a Harmonized Global Minimum Tax
BRENDAN BARGMANN*
In recent years, the international community has acted with
unprecedented cooperation to rationalize, reform, and empower the
international tax regime. Paramount among these reforms is broad
international agreement on a global minimum corporate tax to end the
vicious cycle of competitive tax cuts for the attraction of foreign capital.
This agreement has the potential to revolutionize the international tax
system and to truly reshape the power dynamics between states and the
major multinational corporations who have until now been able to exempt
ever-increasing proportions of their activities from state control.
In 2016, the Organization for Economic Co-operation and
Development (OECD) established a working group-framework-with
over 135 participating countries known as the OECD/G20 Inclusive
Framework On BEPS (BEPS 2.0).1 BEPS is an acronym for Base Erosion
and Profit Sharing, which
refers to tax planning strategies that exploit gaps and mismatches in
tax rules to artificially shift profits to locations with no/low tax rates
and no/little economic activity, resulting in: little or no corporate
tax being paid [and] annual revenue losses for governments of at
least $100 - 240 billion USD, equivalent to 4 - 10% of global
corporate income tax revenue.2
These countries have collaboratively produced a historic international
tax package, agreed to by over 135 countries, to place multilaterally agreed
* J.D. Candidate at California Western School of Law, where his research focuses on
international financial services regulation. Prior to law school, Brendan worked in the intersection of
law, government, and business, in a career that has stretched from the European Parliament to
Capitol Hill. Focused primarily on U.S. campaign finance, Brendan directed numerous record-setting
finance programs that funded successful federal campaigns, political parties, and national political
organizations.
1. OECD, OECD/G20 INCLUSIVE FRAMEWORK ON BEPS 1 (2018),
https://www.oecd.org/tax/beps/flyer-inclusive-framework-on-beps.pdf. The OECD, or the
Organization for Economic Co-operation and Development, is an intergovernmental organization
with 38 member countries which are committed to democracy and the market economy by providing
a platform to compare policy experiences, seek answers to common problems, identify good practices
and coordinate domestic and international policies of its members. About the OECD, OECD (2022),
https://www.oecd.org/about.
2. Id.](ViewImageLocal?handle=hein.journals/vajoillw64&div=1&collection=&method=preview&ext=.png&size=3)
What Is HeinOnline?
Contact us for annual subscription options:
Already a HeinOnline Subscriber?
profiles profiles most
Contact us for annual subscription options:
Already a HeinOnline Subscriber?
profiles profiles most
Contact us for annual subscription options:
Already a HeinOnline Subscriber?
profiles profiles most