The subordination clause in the new tax treaty between the Netherlands and Belgium that grants primacy to the Pillar 2 Directive
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 treaty shall prevent the application (…) of Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of…