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Pramod Kumar Siva

To Tariff or Not to Tariff? That is the Question (before the U.S. Supreme Court)

Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programIn response to a question from some of our non-U.S.-educated tax law…

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 After a decade shaped by the OECD’s BEPS project and successive EU directives aimed at curbing tax avoidance, European policymakers are recalibrating around competitiveness, simplification and…

 CUSTOMS AND EXCISE, DIRECT TAXATION, EU LAW, INDIRECT TAXATIONPlease find below a selection of articles published this month (October 2025) in Highlights & Insights on European Taxation, plus one…

By Pramod Kumar Siva and William Byrnes of Texas A&M Law1. Previous Comments, Recommendations, and Policy Analysis to the OECD and UNPramod Kumar Siva and I have been closely following and engaging…

1. IntroductionThe global minimum tax (Pillar Two) was implemented in the European Union in December 2022 through Directive (EU) 2022/2523 . At its core lies a system of “top-up tax” whereby the…

Highlights & Insights on European Taxation Please find below a selection of articles published this month (September 2025) in Highlights & Insights on European Taxation, plus one freely accessible…

  A Münster Fiscal Court’s late 2023 judgment illustrates a structural fault line in European tax law: while EU law promises free movement of capital, national courts continue to prioritize domestic…

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