Why all top-up tax variants in the EU Pillar Two Directive collide with the EU’s fundamental freedoms (and how to solve this) - Kluwer International Tax Blog

Why all top-up tax variants in the EU Pillar Two Directive collide with the EU’s fundamental freedoms (and how to solve this) - Kluwer International Tax Blog

Maarten de Wilde[1] and Ciska Wisman[2] Summary In this contribution, the authors operationalize a concrete numerical example to explain why all top-up tax variants under the EU Pillar Two Directive collide with the notions of the internal market and the fundamental freedoms. The various top-up tax mechanisms under the Directive impose differences in tax treatment... Continue reading