This article aims to analyse how the effective tax rate criteria of the OECD’s Inclusive Framework Pillar Two proposal affects source taxation, particularly with regard to its effects on developing countries as Source Countries.
L.E. Schoueri & B.C. Fettermann Nogueira dos Santos, Effective Tax Rate Criteria and Source Taxation under the OECD’s Pillar Two Proposals, 77 Bull. Intl. Taxn. 9 (2023), Journal Articles & Opinion Pieces IBFD.