By Maarten de Wilde This contribution, based on a presentation at the GLOBTAXGOV Roundtable of 10 June 2026 on the Inclusive
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The Janus Face of Pillar Two: Incentive Restructuring and Constitutional Tension
By Maarten de Wilde This contribution, based on a presentation at the GLOBTAXGOV Roundtable of 10 June 2026 on the Inclusive Framework Side-by-Side (SBS) package of 5 January 2026, argues that Pillar Two has a “Janus-faced” character. Rather than imposing a
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