Q.3 What are the GLoBE rules? What are the challenges in its implementation? (10 Marks)

Mentor’s comment-
  • https://www.financialexpress.com/opinion/globe-rules-making-a-start/2400251/
  • In the intro, mention model rules released by OECD.
  • In the body, mention two pillars of the rules, how it will help in bringing the common principles at the domestic-law and treaty levels to tax income of specified business. In the challenges mention an ambitious timeline, willingness on part of the US lawmakers to embrace a modified GILTI (Global Intangible Low Taxed Income).
  • Conclude by mentioning that this may not be a complete solution to the challenge of taxing digital companies, it establishes a floor for competition among nations on tax rates
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