Abstract
The OECD approach to reduced taxation of multinational enterprises (MNEs) led to the release of “nexus rules” (Pillar One) and “profit allocation rules” (Pillar Two). Pillar Two has pulled ahead of Pillar One, and the EU Global Minimum Tax Directive converged with Pillar Two, while the NGEU created an incentive for the EU to create new EU own resources having a regulatory aim which will include the Carbon Border Adjustment Mechanism (CBAM), the EU Emissions Trading System (ETS) as well as the global minimum tax imposed by the Directive. In particular the global minimum tax is imposed by home states which undertake the obligation to tax their own MNEs on their own global profits in a defensive coalition against base erosion and profit shifting.