In addition to reshaping the international tax landscape, the implementation of the Global Minimum Tax rules under Pillar Two has raised new legal questions extending beyond the traditional boundaries of international tax law. This talk examines whether, and under what circumstances, Pillar Two measures may be challenged under international investment treaties by multinational enterprises subject to top-up taxes.
It considers whether measures implementing Pillar Two might be scrutinized under investment treaties, the potential application of substantive investment protections (such as expropriation and fair and equitable treatment) to Pillar Two measures, and the practical implications for both states implementing Pillar Two measures and multinational enterprises affected by top-up taxes. More broadly, the talk reflects on what the interaction between Pillar Two and international investment law may suggest for the future design and implementation of international tax rules.
SPEAKER
Dr Xiaorong Li
Lecturer of International Tax Law
Faculty of Law
Kyushu University
Xiaorong (Sharron) Li is a Lecturer at the Faculty of Law, Kyushu University since 2024, after joining as an Assistant Professor in 2023. She holds a Doctor of Law degree from Peking University (2021) and was a guest researcher at the Institute for Austrian and International Tax Law, Vienna University of Economics and Business (Oct-Dec 2018; Oct 2019-Jun 2020). Prior to academia, she worked at PwC Shanghai in international tax structuring and mergers and acquisitions (M&A).
Xiaorong’s research interests lie in the underlying principles governing the allocation of taxing rights, as well as in the intersection between international tax law and broader international law, including international economic law and general international law.
CHAIR
Dr Vincent Ooi
Assistant Professor of Law
Singapore Management University
DETAILS
Date: 4 August 2026, Tuesday
Time: 12.30pm to 1.30pm [Registration commences from 12pm and Lunch will be provided]
Venue: Training Room 1, Tax Academy of Singapore Hub, #01-03, Revenue House [55 Newton Rd, Singapore 307987]
REGISTRATION
Registration Fees:
For Public - $50 (subject to prevailing GST)
Please click HERE to register.
For SMU Staff and Students - Complimentary
Please click HERE to register.
Registration closes on 28 July 2026, 12pm SGT or when the workshop is fully subscribed, whichever is earlier.
ORGANISERS
About Singapore Tax Academy Research Initiative (STARI)
The Singapore Tax Academy Research Initiative (STARI) conducts leading tax law research in a rapidly developing international tax landscape, while also building domestic tax research capacity, developing strong academic networks, and bringing the best in international tax thought-leadership to the tax profession in Singapore. In addition to its research activities, STARI provides training in academic research and writing, and works with the world’s best tax law academics to develop tax professionals.
https://ccla.smu.edu.sg/stari
About Tax Academy of Singapore
The Tax Academy of Singapore is a not-for-profit institution set up by the Inland Revenue Authority of Singapore in collaboration with the international accounting firms – Deloitte & Touche, Ernst & Young, KPMG and PricewaterhouseCoopers, the Singapore Chartered Tax Professionals, the Institute of Singapore Chartered Accountants and the Law Society of Singapore.
As a leading hub for tax excellence and a network of networks, Tax Academy collaborates with leaders in the industry, academia and the government to develop and deliver structured tax training programmes, regular seminars and conferences. Through these platforms, tax professionals can stay current with global developments while enhancing their professional competency, knowledge and capabilities. By fostering exchanges between industry experts, academics and government officials from both local and international spheres, Tax Academy cultivates an environment of continuous learning and knowledge sharing.
https://www.taxacademy.sg
