International Tax and Investment Policy: Navigating Competing Demands
摘要
Since the start of the OECD’s BEPS Initiative, the international tax regime has witnessed an unprecedented degree of multilateralization. While the initiative seeks to increase revenues around the world by reducing tax competition and tax evasion, the situation is more complex for capital-importing economies that use preferential tax regimes to attract FDI as part of their economic development strategy. The Global Anti-Base Erosion (GloBE) rules constrain the policy space of capital-importing economies to offer tax incentives that would reduce the effective tax rate (ETR) of certain multinational enterprises (MNEs) in their jurisdiction below 15%. At the same time, however, international tax policy also contains a reputational dimension that should not be overlooked. This chapter argues that multilateral tax governance confronts policymakers in capital-importing economies with competing demands: while on the one hand participation in multilateral tax governance frameworks may enhance the reputation of a jurisdiction by signalling adherence to best practices in international tax policy, it curtails the scope for offering tax incentives to attract FDI. As a result, policymakers in capital-importing economies need to balance two potentially contradicting policy goals: the ability to safeguard their policy space for investment-oriented tax policy and the reputation of their jurisdiction building on legal and tax certainty and ‘good tax governance’. This chapter maps the interactions of both policy goals under the OECD/G20 Inclusive Framework on BEPS and the 2021 Two-Pillar Solution.