Robert Goulder and professors Allison Christians and Tarcísio Diniz Magalhães discuss the importance of the OECD’s pillar 2 UTPR (undertaxed profits rule) and its place in international tax law. Now ...

Planet Earth made of gold and silver on a concept of the business world. Robert Goulder of Tax Notes and Jefferson VanderWolk of Squire Patton Boggs (US) discuss the problems with the OECD’s pillar 2 ...

Following months of negotiations and speculation, the OECD released a “side-by-side” package on January 5, 2026, which is intended to address U.S. concerns about the global minimum tax (also known as ...

The global tax landscape is experiencing a profound transformation as the OECD/G20’s Pillar Two rules are adopted. Among these, the Undertaxed Profits Rule (UTPR) has emerged as a pivotal mechanism ...

Pillar Two targets multinational enterprises (MNEs) whose aggregated revenue exceeds €750 million in either of the preceding two years out of a four-year period. These enterprises are required to pay ...

House leadership and top Republican tax writers doubled down on their rejection this week of an international tax provision within an Organization for Economic Cooperation and Development (OECD) ...

Pillar Two is part of the two-pillar solution provided by the OECD Inclusive Framework on Base Erosion and Profit shifting that seeks to deter harmful tax practices and tax treaty abuses. A closely ...

Hong Kong Pillar Two introduces the OECD’s 15 percent global minimum tax into Hong Kong law under the BEPS 2.0 framework, effective for fiscal years beginning on or after January 1, 2025. The regime ...

The UAE's Ministry of Finance (MoF) is seeking corporate feedback on the implementation of a global minimum tax in the country. The consultation is open to all stakeholders, but the MoF is ...

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