Critique argues against tax sovereignty objections to Pillar Two’s Global Anti-Base Erosion rules, suggesting flawed comparisons and overstated legal implications.
This article critiques “tax sovereignty” objections to Pillar Two’s Global Anti-Base Erosion (GloBE) rules. It argues that they (i) conflate sovereignty in public international law with fiscal autonomy, (ii) compare an idealized present to a realistic post-GloBE future and (iii) overstate the legal implications of coordinated minimum-tax measures.
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RafaelBarbosade Sousa (2026) studied this question.
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