trying to answer the question raised by the organisers: ' Who is sitting behind the wheel in international tax law ? ' It builds on the author ' s previous publications such as ' EU Harmonization of Tax Nexus: Lessons from Past Experiences ' in E Traversa (ed), The New Tax Nexus in International and EU Tax Law , GREIT Series 15 (IBFD 2022); C Brokelind, ' EU Tax Law and the Return of the Nation-State ' in A Bakardjieva Engelbrekt et al (eds), The European Union and the Return of the Nation State: Interdisciplinary European Studies (Palgrave Macmillan 2020).1 As a follow-up of the implementation by some states of a Digital Services Tax (DST) targeting mainly US MNEs, the US Trade Representative implementing s 301 US Trade Act (1974) initiated the application of 25% tariffs ad valorem on a series of products imported from
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