The Remains of the Day: Rise and Decline of the Pillar I Proposal (and the Making of a New World Tax Order)

The Two-Pillars proposal was arguably to be intended as the Baconian "Pars construens" of the new world tax order as it emerged from the global crisis and the inception of the BEPS project. While, and quite unexpectedly, the second Pillar has been implemented in the several tax jurisdictions, eventually shifting current the debate from policy decisions to be taken to the interpretation of the law as it is, Pillar I seems to be entangled in an extricable situation, and chances to transform it into positive law are more feeble now than ever. Prominent academics and stakeholders have already addressed, in detail, the strength and weaknesses of the Pillar I proposal, including the zeitgeist of the time it was incepted. The goal of this research is to go beyond the technicalities of the Pillar I proposal and of its possible implementation, investigating the policy beneath it.