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This thesis examines legal tensions arising from the interaction between OECD/G20 IF Administrative Guidance and the Pillar Two Directive within the EU legal order. While the Pillar Two Directive remains locked into version of OECD/G20 IF Pillar Two rules as they stood in 2022, the OECD/G20 IF continues to develop its Pillar Two framework through subsequent Administrative Guidance. The thesis exam
