This is a measure that has gone almost unnoticed in the public debate, even though it has sparked intense debate in recent years: the 2024 finance bill transposes into domestic law European Directive No. 2022/2523, itself a result of of the October 2021 agreement signed between members of the Organization for Economic Cooperation and Development (OECD) on the taxation of multinationals.
A provision is thus inserted into the general tax code providing for a minimum tax rate on the profits of multinationals of 15%, a measure that the member states of the European Union must transpose for entry into force on January 1, 2024.
Remember that the OECD agreement is based on two pillars, of which the minimum rate of 15% is the second. The first, which provides for the taxation of companies where they make their profits and targets more specifically digital giants, is still not the subject of an agreement. The initial OECD project is therefore only partially implemented.
Up to 150 billion euros
The first estimates of expected revenues from this 15% rate range from 1.5 to 4 billion euros in France, and up to 150 billion euros globally. This range must be compared with the work of the Fiscal Affairs Department of the International Monetary Fund, which estimates tax losses linked to tax avoidance by large companies at more than $600 billion (around €565 billion). euros) per year. Which made Joseph Stiglitz, 2001 Nobel Prize winner in economics and co-chair of the Independent Commission for the Reform of International Corporate Taxation (Icrict), say: “A rate of 15% is far too low. Within Icrict, we support a rate of 25%. »
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We can only support this position. Even calculated on the possible future harmonized basis that the European Commission would like to see come into force on July 1, 2028, a minimum tax of 15% will not resolve the problem of tax differences between large groups and SMEs. It will not slow down tax competition since, in the name of this rate, we could see a downward alignment of corporate tax rates in the future.
However, this competition weighs more and more heavily on populations, social protection systems, public services and the capacity of public action to face future challenges, particularly environmental ones. We must in fact add to the social financing needs those of ecological bifurcation.
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