The Institute for Austrian and International Tax Law in cooperation with the Doctoral Program in International Business Taxation organized the conference:

The Implementation of the Global Minimum Corporate Tax

It took place from July 4 - July 6, 2024, in Rust (Burgenland), Austria.

The Global Minimum Tax wants to ensure that all corporate profits of multinational enterprises – wherever they arise – are taxed at a minimum rate of at least 15%. In December 2021, the OECD published the Pillar II Model Rules. Several months later, the OECD followed up with a commentary and examples. The EU implemented the Model Rules by enacting a directive in December 2022. Many countries around the world have now implemented an Income Inclusion Rule (IIR) and an Undertaxed Profits Rule (UTPR). The conference will compare different approaches to implementing the OECD Model Rules. It aims to analyze the major challenges regarding the implementation and application of the IIR and the UTPR in the different countries. By focusing on the Qualified Domestic Minimum Top-up Tax (QDMTT), dispute resolution and the compatibility of the Global Minimum Tax with tax and investment treaties, the conference will also discuss to which extent tax incentives are still possible and what the role of the substance based income inclusion will be in the future. Finally, the success and failure of the Global Minimum Tax will be evaluated. 

Please find the conference program and questionnaire below:

Program

Questionnaire

Gallery