Pillar Two and the Tax Policy Challenges of the Substance-Based Income Exclusion
New
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 3
Document
This article critically examines the substance-based income exclusion (SBIE) under Pillar Two, highlighting its conceptual shortcomings, allocative distortions and bias toward tangible-intensive business models. It argues that the current formula inadequately reflects economic reality and proposes alternative approaches for determining routine returns consistent with modern multinational activities.