Maarten de Wilde[1] and Ciska Wisman[2] Summary In this contribution, the authors operationalize a concrete numerical example to explain why all top-up tax variants under the EU Pillar Two Directive collide with the notions of the internal market and the fundamental freedoms. The various top-up tax mechanisms under the Directive impose differences in tax treatment…

 Summary The Court of the European Free Trade Association – the EFTA equivalent of the CJEU – now also is demarcating the room for manoeuvre for the Member States in company tax matters within the scope of the EEA Treaty freedoms by reference to the arm’s-length standard. The EFTA Court does so in the same…