Prix Lehérissel-Dibout du Meilleur Étudiant Fiscaliste 2026

International taxation has been shaped for nearly a century by bilateral treaties and the model conventions developed under the League of Nations and, later, the OECD. The post-war system was built around the principles of residence and source taxation, designed for an economy of physical goods and brick-and-mortar establishments. As multinational enterprises grew and intangible assets (patents, software, data, brands) came to dominate corporate value, the system proved increasingly porous: profit shifting to low-tax jurisdictions, hybrid mismatches, and aggressive transfer pricing eroded national tax bases. Public scandals such as LuxLeaks (2014), the Panama Papers (2016), and the Paradise Papers (2017) accelerated political demand for reform. The OECD/G20 Base Erosion and Profit Shifting (BEPS) project, launched in 2013, produced 15 action items and laid the groundwork for the current two-pillar agreement endorsed by the OECD/G20 Inclusive Framework in October 2021. Pillar One reallocates a portion of the residual profits of the largest multinationals to market jurisdictions; Pillar Two introduces a global minimum corporate tax of 15% through the GloBE rules (IIR, UTPR, and QDMTT). The European Union transposed Pillar Two via Directive 2022/2523, and the rules began entering into force in most EU member states, the United Kingdom, and several other jurisdictions in 2024. Implementation remains uneven. Pillar One's Multilateral Convention has stalled amid disagreement over the scope of Amount A and the fate of unilateral digital services taxes, particularly between the United States and European states. Developing countries, working through the UN Tax Committee and the November 2023 UN General Assembly resolution to negotiate a Framework Convention on International Tax Cooperation, argue that the OECD-led process insufficiently reflects their interests on source taxation, dispute resolution, and taxation of services. The debate today centers on the legitimacy of the standard-setting forum, the balance between residence and source taxation, and the compatibility of minimum taxation with tax sovereignty and investment incentives.