Mechanisms to counteract the erosion of the tax base in the context of globalization: analysis of the two-pillar solution concept

Abstract

In the current environment of the global economy and international relations, the issue of effective taxation of multinational corporations, as well as control over their cash flows and sources of income, is of particular relevance. Given the high level of capital mobility and the proliferation of digital business models, national tax systems are increasingly facing the problem of tax evasion, especially through the transfer of profits to jurisdictions with preferential tax treatment. The development and implementation of effective regulatory mechanisms, including the implementation of the BEPS 2.0 action plan, are critical to ensuring tax fairness and strengthening the fiscal sovereignty of countries.

BEPS 2.0, developed by the Organization for Economic Cooperation and Development (OECD), is aimed at combating negative tax practices of multinational corporations and ensuring stability in international taxation. Its Two-Pillar Solution includes two key elements: Pillar 1 - reforming the rules of profit distribution between countries, in particular in the digital economy; and Pillar 2 - introducing a global minimum level of corporate taxation. These measures are aimed at harmonizing approaches to taxation, ensuring transparency and counteracting tax base erosion. They reflect the need to deeply adapt existing international norms to the conditions of digital transformation of global business. Ukraine actively participates in global tax initiatives, in particular within the framework of the BEPS Inclusive Platform, demonstrating its commitment to integration into the international tax environment and improvement of national legislation in line with current challenges. The implementation of BEPS 2.0 in Ukraine is an important stage in the formation of a transparent, competitive and fair tax system capable of ensuring stable budget revenues, in particular in the context of economic changes and recovery processes.