Document Type

Article

Publication Date

2026

Source Publication

Tax Notes Int'l, vol.121, Jan. 26, 2026

Keywords

Pillar 2; Global Minimum Tax; International Fiscal Law

Abstract

This paper argues that Pillar 2 not only creates a global minimum tax on large multinational enterprises, but also manifests a new international fiscal law regime. Through the lens of a new notion of sovereignty –networked fiscal sovereignty, this paper explains Pillar 2’s raison d’être, technical components and future prospect.

Comments

Jinyan Li is a professor of law and codirector of the LLM tax program at Osgoode Hall Law School of York University in Toronto. She thanks Yuan Liu for her input on this article. In this report, Li argues that pillar 2, while aiming to create a global minimum tax on large multinational enterprises, effectively creates a new international fiscal law regime that is anchored in a new notion of sovereignty.

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