Global Minimum Taxation and International Investment Agreements

The Pillar Two ‘regime’ consists of the rules published by the OECD under the title ‘OECD/G20 GloBE Model Rules’ which represent a non-binding agreement by the participating states to accept the imposition of global minimum taxation at a 15% rate on large multinational corporations in the form of a set of highly technical rules. As such, implementing the Pillar Two rules is liable to create significant burdens for multinational taxpayers that naturally seek to explore legal remedies to reduce the negative impact on their bottom line. This editorial and this special issue are focussed on one particular such remedy, namely the possibility to bring a claim for compensation under international investment agreements (IIAs).