Anti-Abuse Rules in International Tax Law and their Interactions

1. Introduction

The global tax environment has been characterized by constant evolution and changes over the years. From the perspective of tax practitioners, significant shifts in procedures and approaches have been observed, moving from the traditional focus on tax planning and strategies to a greater emphasis on tax compliance, transparency, and the reputation of multinational enterprises (MNEs). When it comes to the countries concerned, thorough discussions and a deep understanding of harmful tax practices were necessary to create mechanisms that protect their tax systems.

In light of these changes and progression, years of in-depth analysis, and the implementation of well-known anti-avoidance measures, collective efforts have enabled a more balanced tax environment. Nevertheless, the impact of globalization is complex and requires continuous assessment to ensure that the goal of a sustainable tax environment is achieved.

As a result of the ongoing discussions, the taxation of the digital economy and the progression of the OECD’s Base Erosion and Profit Shifting (BEPS) Project, parS. 338ticularly Action 1, the Pillar Two Project emerged as an additional measure to address those tax unce...