The Resource The pillar 2 undertaxed payments rule departs from international consensus and tax treaties

The pillar 2 undertaxed payments rule departs from international consensus and tax treaties

Label
The pillar 2 undertaxed payments rule departs from international consensus and tax treaties
Title
The pillar 2 undertaxed payments rule departs from international consensus and tax treaties
Creator
Subject
Language
eng
Summary
In this article, the author argues that the OECD’s model undertaxed payments rule is in effect an undertaxed profits rule and thus departs from the global consensus reached in October 2021 and is incompatible with existing tax treaties
Citation source
In: Tax notes international. - Falls Church. - Vol. 105 (2022), no. 12 ; p. 1401-1409
http://library.link/vocab/creatorName
Li, J. (Jinyan)
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • Pillar 2 (OECD)
  • tax treaty
  • UTPR (OECD)
  • effective tax rate
  • treaty override
Label
The pillar 2 undertaxed payments rule departs from international consensus and tax treaties
Instantiates
Publication
Label
The pillar 2 undertaxed payments rule departs from international consensus and tax treaties
Publication

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