According to the Ministry of Finance, this major reform of the international tax system consists of a two-pillar solution and refers to taxation of digital activities of multinational corporations, as well as application of a minimum global corporate tax rate for large multinational corporations.
Under Pillar One, taxing rights on more than USD 125 billion of profit are expected to be reallocated to market jurisdictions each year. Developing country revenue gains are expected to be greater than those in more advanced economies, as a proportion of existing revenues.
Pillar Two introduces a global minimum corporate tax rate set at 15%. The new minimum tax rate will apply to companies with revenue above EUR 750 million and is estimated to generate around USD 150 billion in additional global tax revenues annually. Further benefits will also arise from the stabilization of the international tax system and the increased tax certainty for taxpayers and tax administrations. The global minimum tax will end tax havens and reduce incentives for multinational corporations to shift profits from developing countries, adds the Finance Ministry.
The Ministry says that OECD estimates of economic impact show that low, middle, and high-income countries will generate additional revenue, while the detailed plan on implementing the two pillars contains ambitious deadlines, i.e. this solution is expected to be implemented by 2023. The agreement is a response to changes resulting from digitalization and globalization that have affected the economies and lives of citizens and the challenges of international business income tax rules that have prevailed for more than a hundred years and have resulted in large multinational corporations not paying their fair share of the tax despite the huge profits that many of these corporations have made.
After intensive talks over aligning the international tax system with the challenges of the 21st century, 136 countries and jurisdictions, including the Republic of North Macedonia and all the countries of the Western Balkans, joined a landmark deal, i.e. the consensus for Pillar 1 and Pillar 2 from The Inclusive Framework on BEPS for addressing the tax challenges of digital economy.