The two-pillar solution: Not a choice, but a compulsion Shifa S. Student, Department of Law, Tamil Nadu National Law University, Trichy, Tamil Nadu, India, (E-mail: shifasharo2003@gmail.com) Online Published on 2 February, 2024. Abstract This paper shall address the allegations of DST being discriminatory against U.S. companies, and elucidate how the allegations were a mere tool to impose retaliatory tariffs to coerce countries into accepting the Two Pillar Solution. The dire need for the U.S. to adopt such coercive methods and the benefits it would reap from the Two Pillar solution will be discussed in detail. In addition, the failure to cater to, and the adverse implications of the Two Pillar Solution on LMICs will be illustrated. Furthermore, the colourable method adopted by India to tax the untaxable shall be analysed in detail. With this, the paper aims to shed light on how the Two Pillar Solution is being put forth as an endeavour to attain a global taxation system, while its design implies otherwise. Top Keywords The Two Pillar Solution, Digital Service Tax, Equalisation Levy, Profit Allocation, Significant Economic Presence. Top |