[Verse 1]
Multinationals shift profits to tax havens offshore
Base erosion schemes drain treasuries worldwide
OECD crafted BEPS to even the score
Two pillars standing tall, nowhere left to hide
[Chorus]
Pillar One reallocates where giants pay
Pillar Two sets floors at fifteen percent
GloBE rules catch profits that slip away
Income Inclusion, Undertaxed Prevention
[Verse 2]
Country-by-Country reports expose the maze
Revenue per nation, substance versus shell
Formulary apportionment rewrites the game
Digital economy taxed where customers dwell
[Chorus]
Pillar One reallocates where giants pay
Pillar Two sets floors at fifteen percent
GloBE rules catch profits that slip away
Income Inclusion, Undertaxed Prevention
[Verse 3]
America's GILTI already hunts low-taxed gold
Controlled foreign companies can't escape the net
CAMT backstops domestic deductions sold
Corporate minimum tax, fifteen percent debt
[Bridge]
When foreign rates fall below the global floor
IIR kicks in, home country collects more
UTPR backstops when parents won't comply
Qualified domestic minimum tax applies
[Chorus]
Pillar One reallocates where giants pay
Pillar Two sets floors at fifteen percent
GloBE rules catch profits that slip away
Income Inclusion, Undertaxed Prevention
[Outro]
Safe harbors shelter well-taxed subsidiaries clean
Substance carve-outs protect real operations
BEPS 2.0 reshapes the global tax scene
Coordination prevents double obligations