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Pillar 2, DSTs and The US Tax Countermeasures

When: Wednesday, July 23, 2025, 3:00 PM - 4:30 PM
Where: Online

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In this seminar, Christos Theophilou and Demis Ioannou briefly discussed problematic issues arising in the context of Pillar 2, such as the compatibility of the UTPR with tax treaties, extraterritoriality and the eligibility of GILTI as an IIR. Then Professor Reuven Avi-Yonah and Professor Błażej Kuźniacki talked about the US reaction to the UTPR and DSTs and the potential for countermeasures such as section 891. Some of the issues discussed were based on Reuven Avi-Yonah and Błażej Kuźniacki’s article entitled “Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures”, available at: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5343459

 

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