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Situation
The international tax system is witnessing a historic reform through the “Two Pillar solution”, negotiated under the auspices of the OECD/G20 Inclusive Framework, whose membership was extended to non-OECD members. The “Two Pillar Solution,” aims to address challenges faced in applying now outdated international tax norms; Pillar One aims to create a new taxing right, and Pillar Two introduces a minimum tax at the rate of 15%. While these reforms have far-reaching implications for developing and developed countries alike, they are significantly complex and the gains for developing countries are modest. Although participation in the Inclusive Framework is on an equal footing for all members, developing countries often lack the capacity to negotiate rules that protect their interests. Given that these rules, if adopted, will remain in force for a long time to come, it is imperative that capacity is built among them to avoid them negotiating away their tax rights and to ensure that they are able to negotiate positions that benefit them as well.
ILPs Action
ILP participated in a G-20 Tax Event hosted by the South Centre to build capacity among revenue officials in India and advise them on the possible approaches under the Pillar One and Pillar Two proposed solution. ILP experts highlighted the differences between the UN approach to taxation of the digital economy and the Inclusive Framework (Pillar One and Pillar Two) solutions for the taxation of the digitalised economy. They also touched on the implications of both solutions for developing countries.
Impact
The Indian revenue officials trained by ILP are now better able to understand the effects of the proposed rules and are better equipped to negotiate improved outcomes for themselves during the formulation of international tax rules. This can help secure increased revenues and positively contribute to achieving their national development agenda and the Sustainable Development Goals. India has since assumed the G20 Presidency and is therefore a leading voice in the Global South. As a result, it has the capacity to create meaningful impact for developing countries during these negotiations.