Covered or Neutralized? GloBE-Rules Impact on Fiscal Instruments - What are the implications?
This thesis examines which fiscal instruments are considered as Covered Taxes under the GloBE Model Rules particularly in the Oil and Gas sector. The countries used for the examination are Brazil and Nigeria as both have a huge oil and gas sector. While Brazil has adopted a Qualified Domestic Top-up Tax, Nigeria has abstained against the Pillar Two framework. The main research question explor