Pillar II

Ana Paula Dourado (General Editor of Intertax) for Intertax

The Contents of Intertax, Volume 51, Issue 08-09, 2023

July 18, 2023

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Reuven Avi-Yonah, Do Intangibles Fit BEFIT? This article argues that the…

Mees Vergouwen (Assistant professor at Leiden University and tax advisor at KPMG Meijburg & Co)

The subordination clause in the new tax treaty between the Netherlands and Belgium that grants primacy to the Pillar 2 Directive

July 13, 2023

Mees Vergouwen[1] On 21 June 2023, the Netherlands and Belgium signed a new tax treaty.[2] Part of (the protocol to) this tax treaty is a subordination clause[3] that provides that "nothing in this…

Ana Paula Dourado (General Editor of Intertax)

The Contents of Intertax, Volume 51, Issue 06-07, 2023

May 31, 2023

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a More…

Ana Paula Dourado (General Editor of Intertax)

The Contents of Intertax, Volume 51, Issue 04, 2023

March 20, 2023

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Stefan Greil, Michael Overesch, Anna Rohlfing-Bastian, Ulrich Schreiber &…

Lisa Zoltowska (Acquisition Manager, Wolters Kluwer, Legal & Regulatory, International Group)

New tax podcast on Pillar 2 - International Law Talk series

March 3, 2023

Welcome to the latest tax podcast in the International Law Talk series. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and…

Ana Paula Dourado (General Editor of Intertax)

The Contents of Intertax, Volume 51, Issue 02, 2023

January 23, 2023

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Victoria Perry, Pillar 2, Tax Competition, and Low Income Sub-Saharan…

Jefferson VanderWolk (Squire Patton Boggs)

The UTPR is Inconsistent with the Nexus Requirement of Tax Treaties

October 26, 2022

By Jefferson VanderWolk Partner, Squire Patton Boggs[1] The GloBE Model Rules were issued in final form in December 2021. No public consultation was undertaken regarding any draft Model Rules, as…

Pedro Guilherme Lindenberg Schoueri (PhD by the Vienna University of Economics and Business and Tax Associate in Sao Paulo), Ricardo André Galendi Júnior (Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)

Who is the “taxpayer” for the IIR and why it does matter

August 16, 2022

1. The IIR and the top-down approach It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a…

Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff), Jorn Steenbergen (Loyens & Loeff )

Enhanced cooperation: EU Implementation of Pillar 2 without unanimity

June 7, 2022

The current state of play in the negotiations for an EU Pillar 2 Directive is that all but one Member State are on board. Hence, there is one “dissenting” Member State left. As unanimity is needed…