We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:A Defence of UTPRThis article defends UTPR (formerly known as the Under Taxed…
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…
On 17 July 2025 the Belgian Constitutional Court requested a preliminary ruling from the Court of Justice of the European Union (CJEU) regarding the compatibility, and by extension the validity, of…
1 IntroductionIn the summer of 2025, under American political pressure, the G7 agreed on an exemption for American business from the global 15% minimum tax (Pillar Two). European…
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…
The authors are winners of the Mitchell B. Carroll Prize for the last two consecutive years, as awarded at the International Fiscal Association global congresses in 2023 and 2024 in Cancún (Mexico)…
Summary
While the U.S. has pulled out from the Global Tax Deal early 2025, threatening taking countermeasures, the latest batch of Inclusive Framework (IF) documents state several times that the IF…
On 22 November 2024 more than 300 tax experts gathered in Rome for the first Italian International tax conference organized by Italian Association of Joint Stock Companies (Assonime). Under the…
