Název práce: Daňová optimalizace nadnárodních korporací: Účinnost minimální daňové sazby

Pivoňková, Alexandra

In October 2021, 137 countries agreed to implement one of the most progressive reforms in the international corporate tax system, the global minimum tax rate of 15 % applicable to all large MNEs effective from January 2024. This study estimates the total amount of top-up tax revenue to be collected through one of the Pillar II mechanisms and assigns these revenues to individual countries based on their current implementation status of the policy rules. Using publicly available CbCR data published by the EU tax observatory, the projected global top-up tax revenue amounts to EUR 141.22 billion, of which EUR 33.62 billion would go uncollected as of the current incomplete implementation of Pillar II. The introduction of long-term carve-outs, the exemptions that decrease the tax base according to real economic substances, decreases the top-up revenue potential by nearly 70 %. The results further reveal that most of the revenues are expected to be collected through the QDMTT mechanism, assigning these extra revenues to the source country where profit is booked. In contrast, the headquarter country rule, IIR, collects only a minimum of top-up revenue for the parent country, as the QDMTT rule takes priority. The simulation of increases in the minimum tax rate to 20 % and 30 % shows a more than...

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