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This book examines the transformative changes in international corporate taxation from 2008 to 2021, culminating in the landmark October 2021 agreement that fundamentally altered multinational business taxation.
The study analyses how the 2008 Financial Crisis and 2020 COVID-19 pandemic catalysed reform through G-20 and OECD initiatives, resulting in a two-pillar framework with conditional mismatch rules and a 15% minimum Effective Corporate Tax Rate applied country-by-country.
Through empirical, comparative, and meta-historical analysis, the author reveals the decisive influence of the Transnational Tax Policy Community (TTPC) as agenda-setter, adviser, and gatekeeper. Despite the TTPC's significant role, the research demonstrates that domestic politics substantially impact implementation and enforcement outcomes.
The work introduces a Dynamic Model of Corporate Tax Governance that not only explains recent revolutionary changes but also predicts future developments in global tax governance, illuminating the ongoing tension between multilateral cooperation and state sovereignty in international taxation.
List of contents
Acknowledgments Commonly Used Abbreviations Introduction Chapter 1: The GCTR, Theories, and the Proposed Dynamic Model Chapter 2: The Creation of the "International" Tax Regime, 1920-1963 Chapter 3: The Tax Challenges of Globalization and the Changing Digital Economy, 1963-2000 Chapter 4: The Evolution of the GCTR, 2008-2021 Chapter 5: Causes of Change in the GCTR, 2008 - 2021
About the author
Michael F. Motala, JD, PhD, is an Assistant Professor of Law at the University of Tulsa College of Law who teaches advanced contracts, securities, taxation, and corporate law, and serves as the Director, Taxation for the G20 Research Group and G7 Research Group at the University of Toronto's Munk School of Global Affairs. Michael's primary expertise is in the global governance of international corporate taxation and its intersection with international economic law, and he has taught, conducted advanced research, and studied in the United States, Canada, the United Kingdom, Switzerland, and France.
