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Europe > Bermuda

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Cover IMF Working Papers
Deciphering the GloBE in a Low-Tax Jurisdiction
Shafik Hebous
,
Cory Hillier
, and
Andualem Mengistu
Pillar Two rules of the Inclusive Framework agreement on a minimum corporate tax (known as ‘Global Anti-Base Erosion Rules’, for short GloBE) have important implications for the design of the corporate income tax. This chapter discusses these implications particularly from the perspective of low-tax jurisdictions. It argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. Importantly, if no profit tax already exists, countries need to consider whether to adopt one, and if yes, in what form. There is a case for introducing a general profit tax beyond the GloBE rules, together with a qualifying GloBE domestic minimum top-up tax as a backstop. The familiar alternatives of efficient economic rent tax designs, however, are no longer equivalent under the GloBE. In practice, given the specifics of the rules, an efficient rent tax on in-scope multinationals cannot be combined with a statutory tax rate below a certain cutoff, because the minimum tax becomes always binding. Under the GloBE, immediate expensing particularly maintains the time-value of fully deducting the cost of investment, without impacting the GloBE effective tax rate.
Keywords:
Investment; Minimum Tax; Tax Competition; Rent Taxation; Cash-Flow Tax; International Taxation; scope multinational; profit tax; top-up tax; tax design; Corporate income tax; Allowance for corporate equity; Corporate taxes; Tax allowances; Global
Cover Global Financial Stability Notes
Private Equity and Life Insurers
Fabio Cortes
,
Mohamed Diaby
, and
Peter Windsor
This Global Financial Stability Note studies the growing trend of private equity (PE) investments into the life insurance industry. PE companies’ investments in life insurers are integral to their strategic growth as PE firms evolve beyond the traditional leveraged buyout transaction to acquire diverse businesses across private credit, structured credit, private real estate funds, and private infrastructure funds. This note reviews the growth in PE investments through the lens of the diverse acquisition incentives and strategies, the consequent changes to asset allocation and investment strategies of the acquired life businesses, and potential prudential and policy implications.
Keywords:
private equity; life insurance; leveraged buyout transaction; private credit; structured credit; private real estate funds; private infrastructure funds; life insurer; private equity company; life insurance insurance company; PE company; IMF Library; Global Financial stability note; Insurance companies; Insurance; Credit; Financial statements; Asset allocation; Global
Cover IMF Working Papers
Digital Tokens: A Legal Perspective
Mr. José M. Garrido
Tokens are units digitally represented in a distributed ledger or blockchain. The various uses of this technology have the potential to transform a wide array of economic activities, from traditional commercial transactions to sophisticated financial undertakings. This paper explores the similarities and differences of tokens with traditional legal instruments in commercial law and how tokens could offer superior solutions, provided that proper legal foundations are established for their operation, including aspects of the law of securities and consumer protection law.
Keywords:
Tokens; Commercial Law; Securities Law; Fintech; Consumer Protection; token taxonomy; non-fungible token; del Mercado de Valores; digital signature; token offering; aspects of the law of securities; Securities; Blockchain and DLT; Smart contracts; Virtual currencies; Securities regulation; Global