The Global Minimum Tax: critical-reconstructive insights. Redistributive purpose of the tax?

Globalisation and digital innovation have led to profound rethinking of taxation. It is well known that the taxation systems at international, European Union, and national levels have struggled to adapt swiftly to the evolving socio-economic landscape. This lag has paved the way for economic entities to engage in aggressive tax planning strategies aimed at maximising their profits. In the era of globalisation, multinational corporations and digital giants have, at times, engineered artificial corporate structures designed to significantly reduce—or even eliminate—their tax liabilities across various jurisdictions. In other instances, they have exploited discrepancies within international tax regulations to secure substantial tax benefits. The Global Minimum Tax certainly remedies the frequent tax planning carried out to date, but it is not immune to considerable application difficulties and systematic inconsistencies. In extreme synthesis, we will focus on the substantive and applicative profiles of the new tax, attempting to assess how the criterion of allocation between taxing powers can be realised, and how fiscal sovereignty, currently in crisis, can take on new connotations.