Abstract
The traditional international tax rules have been insufficient for today's globalized world. To address this issue, the
OECD/G20 Inclusive Framework on BEPS has reached an agreement on the Two-Pillar Solution. The Pillar 2 introduces GloBE rules and provides a minimum 15% tax on corporate profits, putting a floor on tax competition. The implementation of Pillar 2 could remove ineffective tax systems. However, the compatibility of UTPR with international treaties may depend on their specific terms. UTPR may also conflict with other international law obligations. All countries should analyse possible impact and develop appropriate policy and legislative responses. As the Pillar 2 framework is essentially only a soft law instrument implemented domestically, a multilateral treaty may be the most straightforward solution.