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…
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 fundamental overhaul of the international tax system as we know it. As time passes, the international community has time to digest these possible…
Prof.M.F. (Maarten) de Wilde[1] Summary Yesterday, on 14 March 2022, the OECD published the Commentary on the Pillar 2 Model Rules, the global minimum rate for large multinationals. When reading the first pages, the author was overwhelmed by the urge to write this opinion and, ‘equally, however’, to make a connection with an animal farm….
Welcome to the second tax post in the series of International Law Talk. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer Tax Blog, we will…
