Document Type
Article
Publication Date
1-2023
Abstract
On December 15, 2022, the Council of the EU unanimously adopted a directive implementing pillar 2 of the OECD/G-20/inclusive framework base erosion and profit-shifting 2.0 project. Given that the United Kingdom is also going ahead, and several other countries (for example Australia, Canada, New Zealand) are likely to go ahead, this step renders it likely that pillar 2 will come into effect outside the United States. It therefore becomes important to address the interaction between the UTPR (now known as the undertaxed profits rule) and tax treaties, even though both EU directives and national legislation in the United Kingdom can override treaties.
Recommended Citation
Avi-Yonah, Reuven S. "The UTPR and the Treaties." Tax Notes International 109 (2023): 45.
Comments
Reprinted with the permission of Tax Analysts.