After the silent collapse of Pillar One earlier this summer, as it now seems, the question as to what’s next seems to be moving up business agendas and political agendas. On an informal meeting of…
Introduction
Throughout my professional life, I have worked with international tax law. Consequently, I have witnessed various trends and tendencies for more than a quarter of a century. The period…
Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Leonie Fischer, Jessica M. Müller & Christoph Spengel, The Distorting…
Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…
1. Background
In the article Is the Multilateral Instrument (MLI) Really Multilateral? published in the book A Multilateral Convention for Tax – From Theory to Implementation of the Wolters Kluwer…
On April 5, 2021, U.S. Treasury Secretary Janet YELLEN “grabbed the attention of the occupants of corner offices worldwide with a speech to the Chicago Council on Global Affairs. The headline was a…
Summary
There might be a leak in the OECD’s global minimum tax proposals (GLOBE; Pillar Two). To address the remaining challenges of base erosion and profit shifting (BEPS) by large multinational…
As the Blueprint on Pillar I illustrates, the political and technical complexities inherent to the solution sought by OECD are of such magnitude, that such a sole fact opens the window to an…
