Presentation at the IBDT (São Paulo)

On October 1, 2026, Prof. Englisch gave a presentation at the Brazilian Institute of Tax Law (IBDT) in São Paulo on the implications and future of Pillar 2 minimum taxation. His key conclusions: We will have an international minimum tax system at least until the end of the decade, but it will be more fragmented than originally intended and reduced to a purely anti-BEPS instrument. Pillar 2 is no longer designed to meaningfully curb international tax competition beyond the transfer of profits without substance (“BEPS”). This brings so-called “decluttering” to the forefront; however, this requires a context-specific analysis to determine whether Pillar 2 serves as a replacement for or a supplement to the respective specific anti-abuse rule. The discussion with the three colleagues who commented on the presentation then focused on the income-based tax breaks that are popular in Brazil.