The International Tax Regime at 100: Reflections on the OECD's BEPS Project
Journal
International; OECD
Bulletin for International Taxation 2021 (Volume 75), No. 11/12
This article will consider the outcome of Pillars One and Two in light of the history of international taxation since the foundation of the international tax regime. It will consider how Pillar One avoids the PE requirement, and the ways in which Pillar Two implements the single tax principle.