This article focuses on the justification and limits set by international tax law for provisions that result in corresponding taxation in two or more states. “Corresponding taxation" refers to provisions that create a dependency between the domestic tax laws of two states, such as the credit method, subject-to-tax clauses, hybrid mismatch rules or – in future – the minimum taxation (Pillar II). As a result, states are restricted in the freedom to shape their tax policy, i.e. their tax sovereignty, which is desirable to a certain extent and justifiable under international law. The question that is still unanswered, however, is where to draw the line for these dependencies and restrictions.
