2021. 10. 14. 13:00
Hungary, Estonia and Ireland have also joined the global minimum tax agreement, so the new regulation is already backed by all members of the Organization for Economic Co-operation and Development and the G20. Together with the G20, a total of 136 countries participate in the agreement, which together account for 90% of global GDP.
One of the most serious problems of globalization in recent years has been the mapping of the operations of large international corporations across national economic boundaries to national tax systems. Simply put, multinational corporations have improved their financial operations in recent decades, as they have done with their value creation operations. They have developed the most economically advantageous assortment for them in designing global production systems, value chains, and supply networks, and in organizing their financial operations. In their decisions, they naturally chose the options that benefited them. This has often given rise to global models of tax improvement due to differing national tax systems, with many countries losing out in one way or another through the loss of tax revenue.
Through the first pillar of the landmark agreement, it will also reallocate more than $125 billion in profits to some of the world’s 100 largest and most profitable multinational corporations, ensuring that these companies also play their part in bearing the tax burden wherever they operate and turn a profit.
The second pillar of the Global Minimum Tax Agreement is not about eliminating tax competition, but rather about setting mutually agreed limits. OECD estimates allow participating countries to collect a total of about $150 billion in tax surpluses each year. Pillar Two sets the minimum corporate tax rate at 15%, and global corporate taxation is currently set to work as follows:
In the event that a country has a corporate tax rate below this limit, other countries are entitled to an additional tax, so the countries participating in the agreement – and possibly setting a lower tax rate – will not be obligated to implement the minimum tax rate of 15%, so they can It remains in effect in Hungary, where the current corporate tax rate is 9%.
For large corporations that for some reason will not be subject to the above additional tax (for example, because they have real economic activity in the country), the agreement may refuse to apply the benefits of the tax base or introduce tax base adjustment factors that would further modify the tax base to avoid paying Corporate tax to below the minimum.
The second pillar also applies mainly to multinational companies with a turnover of more than 750 million euros, but the participating countries may choose to apply the new rules to large companies located in that country with a turnover of more than 750 million euros. not accessible. .
In contrast to the above, the latest draft of the agreement already includes a reduction in the tax base. Accordingly, the depreciation of tangible assets owned by companies and corporate wage payments will be deducted from the tax rate using a special method of calculation, so that companies that do not engage in fictitious activities involving actual payment of assets and wages can benefit from that benefit and then purchase. Under the agreement, an amount equal to 5 percent of the value of property, plant and equipment and wage payments is not taken into account when determining the minimum corporate tax base.
The objective of the OECD is to sign a multilateral agreement on the above in 2022, which will be implemented in 2023 by the respective member states, including Hungary. At the same time, the agreement allows for a transition period of 10 years from its implementation, during which a better reduction of the special tax base will be applied. The OECD working group plans to work out the details in November this year.
“From Hungary’s point of view, we have been able to turn the regulations into a more favorable direction than before, but the details are still being worked out, so it will take time for the companies involved to implement the changes in the long-term business model,” said Palaz Karacsoni, director of taxation at BDO. Hungary: “Businesses need to prepare for the fact that the agreement will lead to a lot of changes in their operations that will require a reorganization of business processes.”
