OECD

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:Sourcing the Unsourceable: Cross Border Tax Implications of Cryptographic…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:‘Gross’ly Overlooked: The Difficulties of Implementing the New Article 12AA…

A widely accepted view in contemporary tax literature is that international taxation is increasingly shifting toward multilateralism. This article argues that the current evolution reflects not the…

1.0          Introduction:In International Taxation Landscape, Permanent Establishment (PE) taxation has always been a topic of evolving dimensions. Article 5 of OECD MC deals with PE and its…

The OECD's release of the "Side-by-Side Package" on 5 January 2026 marks a watershed moment for the Global Minimum Tax (GMT). After months of painstaking multilateral negotiations, which likely…

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…