IntroductionOn 5 January 2026, the OECD Inclusive Framework announced what many have heralded as a breakthrough: the Side-by-Side (SbS) Package. The package was presented as evidence of the maturity…
1. IntroductionAfter lengthy discussions at OECD/Inclusive Framework level, the Global Minimum Tax Rules – or Pillar Two rules – were adopted on 20 December 2021. Two days later, the European…
IntroductionThe publication of the OECD Pillar 2 Side-by-Side (SbS) Package marks a decisive moment in the evolution of the Global Minimum Tax (Pillar 2 or GloBE ) and its interaction with EU…
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…
This contribution analyzes the recent instability and uncertainty affecting the international tax landscape as of mid-2025 and identifies the key items to monitor regarding the evolution of the…
The Luxembourg High Administrative Court has rejected an appeal against a first instance decision that a holding company resident in Luxembourg had no permanent establishment in Malaysia within…
On 12 December 2022, Zbyněk Stanjura, Minister for Finance of Czechia, in representation of the EU Council, announced the implementation of the OECD Pillar Two in Europe in this way: “I am very…
Maarten de Wilde[1] and Ciska Wisman[2]SummaryIn this contribution, the authors operationalize a concrete numerical example to explain why all top-up tax variants under the EU Pillar Two Directive…
IntroductionOn 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax…
