Abstract
This article focuses on Pillar Two’s substance-based income exclusion and illustrates how it is the result of three separate international tax developments that have taken place over the past 15 years. This article argues that by allowing countries to include this exclusion in their minimum taxes, policy makers and politicians have built an escape hatch into Pillar Two that would allow certain jurisdictions to keep their tax rates low, despite headlines proclaiming the end of tax competition.
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