Pillar 2 an analysis of the IIR and UTPR from an international customary law, tax treaty law and European Union law perspective Filip Debelva, Luc De Broe
By: Debelva, Filip
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Contributor(s): De Broe, Luc.
Material type: 
ArticleSubject(s): FISCALIDAD INTERNACIONAL | SEGUNDO PILAR (OCDE) | IMPUESTO DE SOCIEDADES | TIPO MÍNIMO GLOBAL | UTPR (OCDE) | APLICACION | DERECHO COMUNITARIO EUROPEO | CONFLICTOS JURISDICCIONALES
In:
Intertax v. 50, n. 12, December 2022, p. 898-906Summary: This article discusses potential jurisdictional conflicts between the Pillar 2 rules and international customary law, taking into account potential frictions with tax treaty law and European Union law. In addition, the authors assess whether the Pillar 2 rules can be justified in the same way as controlled foreign company (CFC) rules, thereby referring to the principle of personality. Part three of the article evaluates how conflicts between the Pillar 2 rules and international law are to be resolved. The authors conclude by providing potential solutions to resolve jurisdictional conflicts.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2022/12-4 (Browse shelf) | Available | OP 2141/2022/12-4 |
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| OP 2141/2022/12-1 GloBE rules and tax competition | OP 2141/2022/12-2 Some EU and tax treaty law considerations on the draft EU Directive on Global Minimum Taxation for Multinationals in the Union | OP 2141/2022/12-3 Do GILTI + BEAT + BMT = GloBE? | OP 2141/2022/12-4 Pillar 2 | OP 2141/2022/12-5 The DEBRA Directive and its interplay with Pillar 2 | OP 2141/2022/12-6 Assessing the impact of Pillar Two on developing countries | OP 2141/2022/1-3 Brexit |
Resumen.
This article discusses potential jurisdictional conflicts between the Pillar 2 rules and international customary law, taking into account potential frictions with tax treaty law and European Union law. In addition, the authors assess whether the Pillar 2 rules can be justified in the same way as controlled foreign company (CFC) rules, thereby referring to the principle of personality. Part three of the article evaluates how conflicts between the Pillar 2 rules and international law are to be resolved. The authors conclude by providing potential solutions to resolve jurisdictional conflicts.
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