Roshni Kiran Kumar Dumpala, O.P. Jindal Global University
ABSTRACT
The international tax landscape has undergone a profound evolution in recent years, driven by the imperative to address the challenges posed by the digitalization of the global economy. In response to growing concerns surrounding base erosion and profit shifting (BEPS), the OECD/G20 Inclusive Framework (IF) embarked on a comprehensive initiative to devise solutions aimed at fostering tax transparency and fairness. Among the key pillars of this initiative is Pillar Two, which seeks to establish a global minimum tax framework to combat tax avoidance and ensure that multinational enterprises (MNEs) pay their fair share of taxes. As nations around the world grapple with the complexities of implementing Pillar Two, it is imperative to assess its feasibility and equity, particularly in the context of countries like India. This paper is divided into 2 parts; By examining the historical evolution of Pillar Two, elucidating its objectives and components, and exploring the implications of its implementation, the first part (PART A) will offer insights into the feasibility of integrating these global tax reforms into India’s domestic tax framework. Then through a comprehensive evaluation of the opportunities and challenges inherent in adopting Pillar Two, part 2 and 3 (B & C ) aim to contribute a nuanced understanding of India’s role as a developing nation, in the evolving international tax regime and the broader implications for global tax policy.
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