International Taxation, Globalization, and the Economic Digital Divide.

The article focuses on the evolution of the international tax regime (ITR) over the past century, highlighting the decline of the original ITR from 1980 to 2009 due to globalization, digitalization, and increased tax competition, which undermined tax revenues and social safety nets. It then examines the creation of a new ITR since 2010, featuring measures such as the Foreign Account Tax Compliance Act (FATCA), the OECD's Base Erosion and Profit Shifting (BEPS) initiatives, and the 2021 BEPS 2.0 framework with its two pillars designed to address tax avoidance by multinational enterprises (MNEs) and ensure a minimum global tax rate. The article also discusses the implications of the new ITR for developing countries, noting that while Pillar One benefits large developing markets by reallocating taxing rights to consumption locations, Pillar Two's minimum tax may limit tax competition but could ultimately support developing countries' revenue without significantly restricting their fiscal autonomy.