This book critically examines the GloBE Model Rules, focusing on their justification and structural expressions. By employing a legal dogmatic or doctrinal methodology, it identifies that the primary aim of these rules is to establish a floor to tax competition, a goal that overrides other potential justifications and significantly influences their design. The analysis reveals that while these rules align with the objective of minimizing tax competition, they present challenges in harmonizing with traditional nexus rules and tax policy principles.
