Pillar Two and the standard of equity among nations: a review of the distributional effects of the global minimum tax

Abstract

This article examines Pillar Two from the perspective of the standard of equity among nations. Its objective is to assess, from a tax policy standpoint, whether the Global Minimum Tax contributes to a more equitable allocation of the global tax pie or, conversely, whether it may produce regressive distributional effects for developing countries.

Starting from the premise that international tax justice is not exhausted by cooperation alone, but also requires the recognition of redistributive objectives in the allocation of the international tax base, the standard of equity among nations is proposed as a benchmark for assessing whether the new international tax framework adequately reflects the asymmetries among participating States.