Global Minimum Tax: Technical design, Italian and EU Challanges, and the Evolution of International Tax Competition

BEPS remains one of the most pressing challenges for international tax law. The OECD’s Pillar Two, with its 15% global minimum effective tax rate for MNEs above €750 million, marks a paradigm shift from competition on statutory tax rates to a harmonised minimum framework. This thesis examines its implementation in the EU, focusing on Italy as a case study. It analyses the GloBE rules, including IIR, UTPR, QDMTT, the calculation of the ETR, and the function of the SBIE, while assessing the legal and administrative issues faced by Member States. The Italian approach is explored in detail, highlighting the complexities of transposition and the impact on domestic tax incentives. The study also investigates how Pillar Two is reshaping global tax competition, redirecting it towards administrative efficiency, the strategic design of domestic measures, and refundable credits. In addition, it evaluates the role of transatlantic tensions, with the evolving U.S. stance as a potential obstacle to multilateral alignment. Although empirical evidence remains limited due to the early stage of implementation, the thesis stresses that the long-term success of Pillar Two depends on effective cooperation, solid dispute resolution, and the alignment of national policies with common standards. Ultimately, the reform should not be seen as the endpoint of tax coordination but as the beginning of a new phase balancing competition, cooperation, and legal certainty