Global Minimum Tax Fights Need Dispute Resolution Process

Inconsistent application of the global minimum tax rules where several countries claim a taxing right may require use of the mutual agreement procedure—an instrument to resolve cross-border tax issues, a company tax director said Tuesday.

“In our view, the risk of disputes could arise not only between two countries but also between the taxpayer and a top-up tax collecting jurisdiction because of the divergence of interpretation of the rules,” Thomas Quatrevalet, deputy group head of tax at Air Liquide, said at an Organization for Economic Cooperation and Development tax conference.

While companies are allowed to use MAP under tax ...