Introduction of a Global Minimum Corporate Tax

The subject of the study is the initiative expressed in the OECD Statement on the two — component Solution of Tax problems arising in connection with the digitalization of the economy, to develop a mechanism for the application of the minimum corporate tax rate by multinational companies, regardless of which jurisdiction they are registered in. The purpose of the work is to study the relationship between the mechanisms through which it is planned to ensure the collection of the global minimum corporate tax and the analysis of measures implemented by the Russian Federation to counteract tax evasion using offshore jurisdictions. A comparative analysis of the rules provided for by the second component of the Statement on the Two-component Solution of Tax Problems Arising in connection with the Digitalization of the Economy and the changes made by the Russian Federation to tax agreements with Cyprus, Malta and Luxembourg was carried out; the reasons that may hinder the application of the global minimum corporate tax were identified; its potential consequences for the Russian Federation and other states were considered. It is concluded that the concept of a contractual rule (Subject to Tax Rule, STTR) is conceptually equivalent to the adjustments made during 2020–2021. The Russian Federation in the concluded agreements on the avoidance of double taxation. The separate differences existing between them do not contradict the goals of applying the global minimum corporate tax and do not hinder international counteraction to the “erosion” of the tax base.

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