International Tax Advisory Network

Technical papers and tax updates.

Papers published under the Vodexis name, each written and signed by a named author. Published as general information; nothing here is advice.

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Written by

Anna Trifonova

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Technical insight · September 2026

Pillar Two and tax treaties

The unresolved treaty challenges of the UTPR

Argues that consistency with tax treaties is a property of each rule under each treaty rather than of the global minimum tax as a whole: the QDMTT is the least treaty-sensitive mechanism, the Income Inclusion Rule is defensible and more clearly so where the saving clause applies, the Subject to Tax Rule is compatible by construction once in effect, and the Undertaxed Profits Rule remains genuinely contested.

Download PDF10 pages · English

Cite as: Anna Trifonova, ‘Pillar Two and tax treaties: The unresolved treaty challenges of the UTPR’ (Vodexis, September 2026)

Written by

Eric Ellberger

International Tax Advisor

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Technical insight · August 2026

Swiss Pillar Two compliance and reporting guide

A practical overview for foreign-headed MNE groups

A practical overview of the compliance and reporting obligations applicable to Swiss constituent entities of foreign-headed multinational groups under Pillar Two. Particular attention is given to the interaction between international reporting obligations, Swiss notification requirements and domestic filing obligations administered through OMTax.

Download PDF13 pages · English

Cite as: Eric Ellberger, ‘Swiss Pillar Two compliance and reporting guide: A practical overview for foreign-headed MNE groups’ (Vodexis, August 2026)

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