New chapter to open on international taxation

Jonathan Geldart, director-general of the Institute of Directors, said setting the lowest corporate tax rate at 15 percent will remove some of the most extreme examples of tax competition.

"This will make it harder for countries to reduce corporate tax to very low levels just to encourage organizations－typically in the technology and e-commerce sectors－to move their legal entities to such locations purely for tax advantages," he said. "On the other hand, for the companies affected, there will be less incentive to decide location just because of lower taxes."

Geldart said there has been a considerable amount of negative publicity about some extremely successful global companies declaring their profits in a jurisdiction away from their customers in order to take advantage of lower tax rates.

"We believe companies need to look at how all their stakeholders might view what they do, in order to ensure they don't suffer reputational damage from what many consumers have seen as sharp practice," he said.

Geldart said the countries that will benefit the most are those－including the United Kingdom－that have historically had corporate tax rates above the new minimum of 15 percent, regardless of how developed they are.

"What this does do is reduce the ability of any country to just have low corporate tax rates as a way of attracting organizations to move their headquarters," he said. "In reality, international firms will look at a wide range of things when deciding where to locate, including the overall ease of doing business and the availability of customers. But at least it will no longer just be about tax."

He said the incentive for governments to agree to this OECD process is to try to keep highly mobile companies from moving to jurisdictions with very low tax rates.

"To reduce the effect on digital businesses, some commitments have been made as part of the same agreement to move away from specific technology and digital taxes that some countries had adopted in response to public concern," Geldart added.

Ronnie Lins, director of the China-Brazil Center for Research and Business, said the two-pillar plan should theoretically affect research and development-intensive sectors more severely.

However, the "global tax universe" allows for the possibility of carrying out many tax maneuvers. The new international regulations may not work for some companies in certain sectors, and the characteristics of a local tax system and the interest of governments in attracting multinationals should not change that much, he said.

"Take the pharmaceutical and high-tech sectors for example. We find that intellectual property, algorithms, patents－among others－are intangible and R&D-intensive goods. Although they are most affected by the new taxation, they have increased flexibility to implement more favorable tax guidelines for their activities," Lins said.

He added that in theory the sectors that could be most affected are those related to the digital economy. However, the extent to which they are affected will depend on where the companies are located. In addition, the characteristics of the tax system in a particular country will be fundamental for evaluating the outcome of the new international tax system.

Lins said the final implementation of the new tax regime should consider standardizing taxes between countries, and this can only happen in the very distant future.

The new regulations will help many countries. For example, China will be able to carry out deeper tax reforms, better contain tax evasion and create improved conditions to enhance its development, he added.