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Institute for Global Law, Economics and Finance

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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Join us on 23 July, at 16.00 CET/ 15.00 UK/ 10.00 EST for a very interesting online seminar, featuring Professor Reuven Avi-Yonah, Professor Błażej Kuźniacki and Christos Theophilou and Demis Ioannou from our Pillar 2 executive education teaching team.

The Zoom link will be sent via Eventbrite on the day of the seminar.

In this seminar, Christos Theophilou and Demis Ioannou will briefly discuss 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 will talk about the US reaction to the UTPR and DSTs and the potential for countermeasures such as section 891. Some of the issues to be discussed are 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

Don’t miss this topical seminar!

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