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UN
Mukesh Butani (Managing Partner at BMR Legal), Pranoy Goswami, Spandana Koona (BMR Legal)
A Kaleidoscope for an Equitable and just Future: Examining the Merits of the Draft Text of the United Nations Framework Convention on International Tax Cooperation
January 14, 2026

 Addressing entrenched inequalities permeating society, has been the concern of political justice.  So though the term justice has assumed importance in the realm of political science…

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Technology
Jasper Korving (Maastricht University; Deloitte Tax & Legal BV)
Side-by-Side as discordant constitutional element: what can EU Member States do?
January 12, 2026

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…

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City
Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)
The Pillar 2 - Side-by-Side Package: A Structural Breach of EU Tax Law
January 08, 2026

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…

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EU parliament
Giorgio Beretta (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University), Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)
The Contents of Highlights & Insights on European Taxation
January 05, 2026

Please find below a selection of articles published this month (December 2025) in Highlights & Insights on European Taxation, plus one freely accessible article.Highlights &…

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EU parliament
Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)
The EU 28th Regime for Innovative Companies Needs a Dual-Instrument Architecture to stimulate a Coherent Tax Treatment
December 29, 2025

The European Union currently comprises twenty-seven Member States, each maintaining its own rules on company law, labour relations, insolvency and taxation. The European Commission’s proposal for a “…

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City
Maria Amparo Grau Ruiz (Full Professor of Financial and Tax Law, Complutense University of Madrid Visiting Professor of Transnational Taxation, Northwestern University)
Better taxation and public expenditure
December 16, 2025

A new rhythm in international taxation when facing classic problemsIn recent years, the tax world is being shaken at an international level. Historically the negotiation and entry into force of…

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Pramod Kumar Siva
William Byrnes (Texas A&M University Law)
Kumar & Byrnes' Comments on Dispute Prevention and Resolution For UN's Framework Convention
December 08, 2025

Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programWe appreciate the opportunity to provide input on this historic…

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Pramod Kumar Siva
William Byrnes (Texas A&M University Law)
Pillar Two Side-by-Side Challenges of EU Law, Global Tax Governance, Sovereignty. Comments for a Rational Win-Win Path Forward.
December 05, 2025

Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate program.AbstractThe European Union has transposed Pillar Two into EU law,…

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Pramod Kumar Siva
William Byrnes (Texas A&M University Law)
Kumar & Byrnes' Comments With Recommended Text for UN Framework Agreement
December 03, 2025

Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programAbstractWe appreciate this opportunity to provide article-by-article…

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Texas A&M International Tax Risk Management graduate program
William Byrnes (Texas A&M University Law)
Understanding the 2025 Perrigo Decision Through the Lens of a Craps Game
December 01, 2025

On September 25, 2025, Perrigo v. U.S. was decided, marking a significant win for the taxpayer, particularly in the Court’s finding regarding economic substance and risks. The Federal Judge in…

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