Is the US Already Compliant with Pillar 2?

2 Pages Posted: 7 Dec 2022 Last revised: 6 Mar 2023

Date Written: November 8, 2022


This note explains why the US is arguably already in compliance with Pillar 2 of BEPS 2.0 and why the EU and other countries should "take the win" and implement Pillar 2 without subjecting US MNEs to the UTPR or the QDMTT.

Keywords: OECD, Pillar 2, CAMT

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., Is the US Already Compliant with Pillar 2? (November 8, 2022). U of Michigan Public Law Research Paper No. 23-006, Available at SSRN: or

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Do you have negative results from your research you’d like to share?

Paper statistics

Abstract Views
PlumX Metrics