Building the Gateway: Why the Two Pillars Need Each Other

• Autores: Reuven Avi-Yonah, Ajitesh Kir
• Localización: Intertax, ISSN 0165-2826, Vol. 52, Nº. 10, 2024, págs. 591-601
• Idioma: inglés
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• Resumen

  • 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 because in the absence of a clear sourcing rule there is no limit to countries implementing the Qualified Domestic Minimum Top-Up Tax (QDMTT), which would turn off the other parts of Pillar 2 and potentially result in double taxation. Pillar 1 is not going forward in the absence of a Multilateral Tax Convention (MLC), but it can be implemented unilaterally, although that would require overriding existing tax treaties.