In this article in @taxnotes.com I discuss how the Pillar 2 rules deals with the sale of vessels, including a conflation of the notion of control with legal ownership, and the EU State aid dimensioN.

You can find the full article here: lnkd.in/d_iKh7yc

In @taxnotes.bsky.social today I have a piece on the taxation of shipping demurrage and detention charges under double tax treaties and Pillar 2. Link to the article: taxnotes.co/4goRCnS