Building the gateway electrónico why the two pillars need each other Reuven Avi-Yonah, Ajitesh Kir
By: Avi Yonah, Reuven Shlomo
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Contributor(s): Kir, Ajitesh.
Material type: 
ArticleSubject(s): PRIMER PILAR (OCDE) | SEGUNDO PILAR (OCDE) | UTPR (OCDE) | CONVENIO MULTILATERAL
In:
Intertax v.52, n.10, oct 2024, p. 591 – 601Summary: There is a reason the OECD proposed two pillars for its gateway to a better tax future. A gateway requires both pillars, and neither can stand without the other. Pillar 2 is a fait accompli, but it needs countries to implement Pillar 1 as well because in the absence of a clear sourcing rule there is no limit to countries implementing the Qualified Domestic Minimum Top-Up Tax (QDMTT), which would turn off the other parts of Pillar 2 and potentially result in double taxation. Pillar 1 is not going forward in the absence of a Multilateral Tax Convention (MLC), but it can be implemented unilaterally, although that would require overriding existing tax treaties.
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There is a reason the OECD proposed two pillars for its gateway to a better tax future. A gateway requires both pillars, and neither can stand without the other. Pillar 2 is a fait accompli, but it needs countries to implement Pillar 1 as well because in the absence of a clear sourcing rule there is no limit to countries implementing the Qualified Domestic Minimum Top-Up Tax (QDMTT), which would turn off the other parts of Pillar 2 and potentially result in double taxation. Pillar 1 is not going forward in the absence of a Multilateral Tax Convention (MLC), but it can be implemented unilaterally, although that would require overriding existing tax treaties.
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