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What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income? The current version of the United Nations Model Double Taxation Convention…

1. Introduction The Pillar Two Report[1] (the “Report”) which contains the Global Minimal Tax (the “GloBE tax”) proposal has recently been on the top of discussions both in the academic and practice…

1. Introduction The ability to stimulate economic activity and to attract foreign capital and investments through national tax policies has been known for many centuries. It was in the middle of the…

Purpose of the blog The purpose of the blog, which is slightly futuristic, is to discuss whether countries will still compete with one another to attract activities in their jurisdiction post-Pillar…