Introduction of Global Rules for Taxation of Transnational Corporations' Cross-Border Profits: Current Trends

The subject of the study is the legal and institutional foundations for the formation of global rules for taxing the cross-border profits of multinational corporations (MNCs). This includes a comprehensive examination of the historical evolution, substantive logic, and practical implementation of key international initiatives in this area: from the failed UN Code of Conduct for MNCs project at the end of the 20th century to modern OECD reforms (BEPS Plan and the "Two-Pillar Solution") and a new competing initiative—the UN Framework Convention. The focus of attention is on specific legal mechanisms and principles, such as the transformation of the classical "arm's length" principle and the concept of fiscal unity of MNCs, as well as the institutional dynamics of the confrontation between regulatory platforms (OECD and UN), reflecting the global conflict of interest between developed and developing countries. The aim of the work is to conduct a comprehensive analysis of the evolution and current trends in international tax regulation of MNCs, identify key legal contradictions and institutional conflicts, and assess the prospects for creating an effective and fair system. The research is based on a combination of general scientific and specialized legal methods: dogmatic (formal-legal) analysis of international documents; historical-legal methods to identify continuity in approaches to taxing MNC profits; comparative legal analysis of the positions of the OECD and UN; systemic analysis and legal forecasting methods. Results of the work: 1) The cyclical nature of attempts at global regulation has been established, where ambitious projects to revise the foundations of MNC taxation (UN Code of the 1970s, Pillar 1) are replaced by technocratic reinforcement of the status quo (BEPS) or selective innovations (Pillar 2). 2) Asymmetric recognition of fiscal unity among MNCs has been revealed: consolidation is allowed to protect state revenues through the global minimum tax rules (Pillar 2), but rejected for fair redistribution of tax rights (the failure of Pillar 1). 3) An increasing institutional fragmentation between the technocratic, yet legitimately vulnerable OECD model and the legitimate, but weak UN initiative has been discovered, leading to legal uncertainty for taxpayers. Scope of results: The findings can be used in legislative activities when developing national tax policies and positions in international negotiations; in scientific research on international tax, financial, and public law; in the educational process of legal and economic higher education institutions.