Is Pillar Two’s “Devilish Logic” Immune to Legal Challenges?

Pillar Two’s “devilish logic” not only incentivizes countries to join the agreement but also diminishes the economic motivation for taxpayers to challenge the rules. This study explores whether this deterrent effect is based on violations of legal obligations enforceable against the involved jurisdictions. While no breaches of general international law were found, the study identifies potential violations of tax treaty provisions.