Building the Gateway: Why the Two Pillars Need Each Other

Authors

• Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow
• Ajitesh Kir

Document Type

Article

Publication Date

2024

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.

Recommended Citation

Avi-Yonah, Reuven S. and Kir, Ajitesh, "Building the Gateway: Why the Two Pillars Need Each Other" (2024). Public Law & Legal Theory Working Papers. 50.
https://repository.law.umich.edu/pub_law_archive/50