Download This PaperPillar 2 and International Investment Agreements: ‘QDMTT Payable’ Seals An Internationally Wrongful Act
Tax Notes International
21 Pages Posted: 7 Nov 2023
Date Written: October 10, 2023
Abstract
In this report, Kuźniacki analyzes the clash between pillar 2 and international investment agreements, emphasizing the part of the most recent OECD administrative guidance regarding a qualified domestic minimum top-up tax payable and the OECD’s potential liability for related internationally wrongful acts.
Keywords: pillar two, international investment agreements, rule of law, good faith, internationally wrongful act, OECD
JEL Classification: K 34, K 30, K 33, F 42
Suggested Citation: Suggested Citation
Kuzniacki, Blazej, Pillar 2 and International Investment Agreements: ‘QDMTT Payable’ Seals An Internationally Wrongful Act (October 10, 2023). Tax Notes International, Available at SSRN: https://ssrn.com/abstract=4598045
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