The OECD’s Side-by-Side Package: Stabilizing Pillar Two or the Beginning of Fragmentation?

The global minimum tax was never going to be implemented without political compromise. What was unexpected, however, was how central that compromise would become to the future of the OECD/G20 Inclusive Framework itself. The OECD’s Side-by-Side Package, released on 5 January 2026, marks a decisive moment in the evolution of Pillar Two(GloBE)—one that raises fundamental questions about global tax harmonization,

Share
Read more
Understanding the OECD Inclusive Framework, Pillar Two, and the Architecture of the Global Minimum Tax

Understanding the OECD Inclusive Framework, Pillar Two, and the Architecture of the Global Minimum Tax

International corporate taxation is undergoing its most consequential reform in nearly a century. At the center of this transformation is the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS)—a multilateral platform designed to modernize global tax rules for an economy defined by digitalization, mobility of capital, and highly integrated multinational enterprises (MNEs). These reforms are not merely technical.

Share
Read more

Rules of Origin in Trade Agreements: Turning Compliance into Profit

In today’s intricate web of global trade, understanding the nuances of trade agreements is not just a bureaucratic necessity but a strategic asset. At the core of this lies the concept of rules of origin (ROO) – a critical component that determines the economic nationality of a product. For businesses engaged in cross-border trade, mastering the complexities of ROO can

Share
Read more

The German Federal Constitutional Court and the European Stability Mechanism

By: Carsten Lexa The German Federal Constitutional Court in Karlsruhe dismissed motions on Wednesday that sought to block the Euro Zone’s permanent bailout fund, the European Stability Mechanism, or ESM. The ESM is designed to handle bailouts and work in tandem with the European Central Bank to buy the bonds of countries, such as Italy and Spain, that are straining

Share
Read more
1 2