Why Pillar Two Top-Up Taxation Requires Tax Treaty Modification
Prof.dr. M.F. (Maarten) de Wilde[1] Summary On 20 December 2021, the OECD published the announced Pillar Two Model Rules, as part of the envisaged establishment of a global 15% minimum level of company taxation for large multinationals (Pillar 2). No mechanism has been considered to provide for a parallel adaptation of countries’ tax treaty networks…