The UTPR and the Treaties

Tax Notes International, January 2, 2023, p. 45

6 Pages Posted: 10 Jan 2024

Date Written: December 19, 2023

Abstract

In this article, Avi-Yonah explains the interplay between the UTPR and tax treaties, and the role played by customary international tax law, including treaty overrides and soak-up taxes.

Keywords: UTPR, Pillar 2, tax treaties

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., The UTPR and the Treaties (December 19, 2023). Tax Notes International, January 2, 2023, p. 45, Available at SSRN: https://ssrn.com/abstract=4668950

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)

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