From Evolution to Potential Revolution: Explaining the Reform of the Global Corporate Tax Regime from 2008 to 2021
Bibliographic record
Abstract
The two-pillar framework for the taxation of multinational business profits contained in the landmark October 2021 international tax agreement was a major and potentially revolutionary step toward a new Global Corporate Tax Regime (GCTR). The two pillars introduced a rare and substantial departure from long-established and salient norms governing source-based taxation and methods of preventing corporate tax avoidance. It also proposed unprecedented constraints on state sovereignty through new methods of coordinating inter-nation taxing rights. Why was there an abrupt shift to the enduring status quo causing this potentially revolutionary change? How and why has the GCTR evolved from 2008 to 2021, and what is its likely evolution and impact in the future? This study argues that multilateral cooperation on international tax law and policy reform coordinated by the G-20 and OECD was catalyzed by the shocks of the Global Financial Crisis in 2008 and the COVID-19 pandemic in 2020, each of which disrupted the status quo and set in motion a multi-phase causal process and international institution-building that provided a new governance framework, which facilitated this potentially revolutionary change. The original empirical, comparative, and meta-historical analysis in this study demonstrates that the OECD-centered Transnational Tax Policy Community (TTPC) was the primary cause of the regime’s normative development, its influence was strengthened after the 2008 Global Financial Crisis, and it acted as a powerful agenda-setter, adviser, gatekeeper, veto-player, and interlocutor. Yet despite the TTPC’s influential role, this study argues that the international politics of distribution are highly correlated with the implementation of domestic legislative outcomes and enforcement. Thus, considering the significant distributional implications of the two-pillar framework and the proposed constraints on state sovereignty, it is an open question whether the agreement will be comprehensively implemented by the 136 countries that endorsed the October 2021 agreement. This dissertation uses a mixed methods approach and synthetic middle-range analytical framework to develop a Dynamic Model of Corporate Tax Governance that describes and predicts the causes of norm and rule changes in the GCTR. It provides a useful basis for estimating future global tax governance “hard” and “soft” law outcomes.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.004 | 0.008 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.003 | 0.003 |
| Science and technology studies | 0.001 | 0.007 |
| Scholarly communication | 0.003 | 0.006 |
| Open science | 0.001 | 0.002 |
| Research integrity | 0.001 | 0.002 |
| Insufficient payload (model declined to judge) | 0.004 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".