Taxes and geopolitics

Trump's game now has digital service tax in its sights

US suspension of the global minimum tax does not end the tax war

class="conParagraph_R21">class="conParagraph_R21"> Alessandro Galimberti

Afp

3' min read

3' min read

The agreement at the G7 Kananaskis on 25 June that exempts US multinationals from the global minimum tax - 15% worldwide minimum tax rate that will instead continue to affect companies in the other G6 and throughout the EU - is only the first step in America First's tax policy.

In distancing himself from the Global tax deal of the OECD the day after he took office on 20 January, Donald Trump was very clear and explicit: in addition to the OECD policies, which had been suspended by the last Canadian G7, Washington's reaction would reach 'all extraterritorial tax regulations or those that disproportionately affect American companies'. A subtle periphrasis to indicate the Digital taxes that have eroded to a (minimal) extent - and so far in only a few countries, including Italy - the enormous profits of US big-tech.

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Global minimum tax (suspended) and digital tax (in the crosshairs) are in fact two sides of the same coin, but very different. If the first, the Gmt, has to do with market competition - albeit in the bizarre Trumpian perspective - the second, hated even in the 'very liberal' Silicon Valley and also opposed by the Democrats, concerns thegeopolitical and strategic supremacy of the US.

The Global minimum tax

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The idea of taxing multinationals wherever they have head offices and activities was born after the great financial crisis of 2008/09, when the explosion of sovereign debt - also and above all in the stars and stripes - triggered the US policy of 'recall' taxation. First by enacting the Fatca (Foreign Account Tax Compliance Act) in 2010 - which essentially obliges banks and financial intermediaries around the world to transmit to the Internal Revenue Service the accounts and assets of US citizens - and then by leading the OECD to launch the Beps (Base erosion and profit shifting) programme.

The Global Tax Deal that Trump talks about - pointing to him as a sworn enemy of national interests - was born in that context and develops on two levels. The second (Pillar 2) deals precisely with the traditional multinationals, noting that since the early 1970s a policy of tax avoidance (not 'evasion') has developed relentlessly by exploiting the many holes in international rules and treaties. The OECD's idea was then to connect tax jurisdictions - with the automatic exchange of information, which, however, with the US and only with them is not reciprocal - and to imagine a minimum level of global taxation (15%), not necessarily to be paid in a single country but reconstructing the value chain - and therefore taxes - country-by-country.

The reconstruction of the value chain and the calculation of the tax-per-country allocation has frighteningly high compliance and maintenance costs for companies and, moreover, offers in return a derisory revenue (ratio of 12 to 1 according to a study by the University of Mannheim). Costs and taxes from which US companies have been exempted thanks to Trump's 'push' and which, instead, will weigh on EU multinationals (the Union has transposed the Gmt with a directive, making it mandatory for all 27 from January 2024).

The Digital Service Tax

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The real game on taxes - and thus on tariffs - is however played on the other side, the OECD's Pillar 1 designed to 'tax' digital big tech. The US, which has absent-mindedly witnessed the progress of Pillar 2 (which even the Democrats would not initiate, taking refuge behind Trump's tax 'nationalisation' called Gilti), has always been intransigent on Pillar 1: no way. In the meantime, some countries have initiated it (including Italy and France in the G7) by hitting turnover, not earnings generated in the country, with taxes between 2 and 3 per cent.

Results? France collects 780 million per year, Italy 455. Very little. Moreover, more than half of the revenue is off target and affects domestic companies. But this is not enough for Trump and the US. As of 9 July next, retaliation will point in this direction.

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