Prospects for introducing a global minimum tax in Ukraine

In response to the intensification of international tax competition and the shifting of profits by multinational enterprise groups to low-tax jurisdictions, the countries participating in the OECD Inclusive Framework have developed a two-pillar solution. The second component (Pillar 2) envisions the introduction of a global minimum tax. The main goal of this tax is to establish a minimum level of taxation for large multinational groups at 15%, regardless of the jurisdiction in which they operate. This article presents one of the first comprehensive studies of Pillar 2 in Ukraine. It identifies that the mechanism of the global minimum tax has an asymmetric impact: it creates advantages for developed countries, where the headquarters of multinational groups are typically located, while simultaneously limiting the ability of developing countries to use tax incentives as a tool for tax competition. The article explores mechanisms designed to mitigate this effect, including the Subject to Tax Rule (STTR) and Qualified Domestic Minimum Top-up Tax (QDMTT). It is established that, due to the substance-based income exclusion, Pillar 2 favors businesses that rely heavily on the use of tangible assets and human resources. The Ukrainian context is analyzed in detail: it is determined that the implementation of the global minimum tax is an important step toward Ukraine’s EU membership, where such a tax is already in force. The paper stresses the urgent need to introduce QDMTT in Ukraine, which would allow the country to be the first to collect top-up tax from companies operating in Ukraine with an effective tax rate below 15%. Otherwise, Ukraine risks losing additional revenues that could be collected by other countries under Pillar 2. A further priority is the review of the current system of tax incentives, many of which become ineffective under the new rules (e.g., rate-reducing ot tax exemption benefits), and the transition to incentives that defer taxation (such as accelerated depreciation) or encourage investment in fixed assets and job creation.