Abstract
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. Pillar 1 is not going forward in the absence of a Multilateral Tax Convention, but it can be implemented unilaterally, although that would require overriding existing tax treaties.
Disciplines
Tax Law
Date of this Version
3-20-2024
Working Paper Citation
Avi-Yonah, Reuven S. and Kir, Ajitesh, "Building the Gateway: Why the Two Pillars Need Each Other" (2024). Law & Economics Working Papers. 276.
https://repository.law.umich.edu/law_econ_current/276