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Can Pillar Two be Leveraged to Save Pillar One?

Tax Notes International, July 2022

This article sets out a pillar 1 design proposal that leverages pillar 2 to reallocate taxing rights to market jurisdictions and avoid double taxation without requiring amendments to U.S. tax treaties.

Paper

Can Pillar Two be Leveraged to Save Pillar One?

Working paper

WP 22/06 Heydon Wardell-Burrus, A Pillar One Design Proposal: Leveraging Pillar Two

Blog

Deborah Schanz, 25 July 2022 Reducing complexity and compliance costs: A Simplification Safe Harbour for the Global Minimum Tax

Author/s

Heydon Wardell-Burrus