This article investigates the Global Anti-Base Erosion Model Rules (GloBE Rules) not as a minimum tax but as a regular corporate income tax system. Drawing on the framework of analysis set out in the author's 2024 book, Corporate Tax Law, this article compares the GloBE Rules with the features of four archetypal corporate income tax systems—those of China, Germany, the United Kingdom and the United States—with a focus on the first of three artificialities involving corporations: the artificiality of a corporation as an income-deriving subject. The article considers how entities subject to the GloBE Rules are identified and classified, examines specialist tax base issues arising from the artificial nature of the subject matter, and analyses the tax treatment of the subject entity's income. The analysis reveals that while many features of the GloBE Rules are broadly familiar to students of regular corporate income tax systems, a number of peculiarities emerge, including the unusually broad scope of entity coverage, the distinctive treatment of losses through deferred tax accounting, and the unconventional allocation of tax liability to individual Constituent Entities.
SPEAKER
Professor Peter Harris
Professor of Tax Law;
Chair of the LLM Examiners
University of Cambridge
Peter A. Harris is a solicitor whose primary academic interest is in tax law. He is a Professor in Tax Law at the Faculty of Law of the University of Cambridge, United Kingdom and Director of Studies and Fellow of Churchill College. He earned a Doctorate of Philosophy and a Master of Laws from the University in 1996 and 1992 respectively (Darwin College), as well as a Bachelor of Laws (Honours) from the University of Queensland in 1991. Previously, Prof Harris was a Senior Lecturer at the Law Faculty of the University of Sydney. From January 1999 until July 2000 he served in the Washington D.C. based position of Technical Assistance Advisor for the Legal Department of the International Monetary Fund where he engaged in drafting income tax laws for developing countries. He continues to advise for the IMF as an external consultant. He has taught tax law (mainly as a visiting professor) at numerous universities including the University of Georgetown, the University of Sydney, the University of Leiden, Ecole Nationale des Ponts et Chaussées (Paris), the University of Florida, the University of Pretoria, the University of Auckland, the University of Melbourne, the Vienna University of Economics and Business, Utrecht University, the Norwegian School of Management, the Queensland University of Technology and London University. Prof Harris has had a consultancy arrangement with KPMG London since 2001. Since 2013 he has acted as a consultant for the Financing for Development Office of the UN.
CHAIR
DETAILS
Date: 4 September 2026, Friday
Time: 12pm to 1pm [Registration commences from 11.30am and Lunch will be provided]
Venue: Training Room 3, Tax Academy of Singapore Hub, #01-03, Revenue House [55 Newton Rd, Singapore 307987]
REGISTRATION
Registration Fees:
For Public - $50 (subject to prevailing GST)
Please click HERE to register.
For SMU Staff and Students - Complimentary
Please click HERE to register.
Registration closes on 25 August 2026, 12pm SGT or when the workshop is fully subscribed, whichever is earlier.
ORGANISERS
About Singapore Tax Academy Research Initiative (STARI)
The Singapore Tax Academy Research Initiative (STARI) conducts leading tax law research in a rapidly developing international tax landscape, while also building domestic tax research capacity, developing strong academic networks, and bringing the best in international tax thought-leadership to the tax profession in Singapore. In addition to its research activities, STARI provides training in academic research and writing, and works with the world’s best tax law academics to develop tax professionals.
https://ccla.smu.edu.sg/stari
About Tax Academy of Singapore
The Tax Academy of Singapore is a not-for-profit institution set up by the Inland Revenue Authority of Singapore in collaboration with the international accounting firms – Deloitte & Touche, Ernst & Young, KPMG and PricewaterhouseCoopers, the Singapore Chartered Tax Professionals, the Institute of Singapore Chartered Accountants and the Law Society of Singapore.
As a leading hub for tax excellence and a network of networks, Tax Academy collaborates with leaders in the industry, academia and the government to develop and deliver structured tax training programmes, regular seminars and conferences. Through these platforms, tax professionals can stay current with global developments while enhancing their professional competency, knowledge and capabilities. By fostering exchanges between industry experts, academics and government officials from both local and international spheres, Tax Academy cultivates an environment of continuous learning and knowledge sharing.
https://www.taxacademy.sg
