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…
The Pillar 2 initiative (GloBE and QDMTT) has been seen as the end of using low effective corporate income tax rates (either by virtue of low nominal corporate income tax rates and/or through the use…
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…
Issues involving controversy surrounding the operation of the newly devised Pillar Two rules in company taxation seem to have moved strikingly up business agendas and political agendas recently…
