Global Tax Disputes Loom Large Without Strong Resolution Tool

The design of the global minimum tax is making large multinational companies vulnerable to disputes with countries all over the world—and halfway into 2024, there’s no tool to resolve them.

The tax’s model rules, which took effect in January, were written to be incorporated into countries’ local laws. But the rules and their accompanying administrative guidance, which spans hundreds of pages, have been adopted in different forms by three dozen countries.

The differences will lead to inconsistencies and, inevitably, lengthy disputes with companies and other countries over how much tax is owed, tax professional warn.

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