International Tax Law in the Age of Geoeconomics

This study examines the evolving landscape of international tax law amid the rise of geoeconomics, where economic instruments are increasingly wielded for geopolitical ends. Once a technical domain, tax policy now finds itself at the heart of global power struggles, with norms shaped by strategic interests, coercion and competition among states. Analysing recent developments, including tariffs, the OECD’s Pillar Two rollout and digital services taxes, the study highlights the growing interplay between tax, national security and economic statecraft. The distinction between risk and uncertainty is revisited, revealing new challenges for policymakers and taxpayers as tax measures become entwined with broader political and economic agendas. Ultimately, the study argues that geoeconomics offers a vital framework for understanding the complexities and uncertainties now facing international tax law, urging a shift from isolated technical analysis to holistic policy assessment.