This article examines the current status of the OECD’s two-pillar reform of the international tax system to address the tax challenges arising from digitalization and globalization of the economy, agreed to in October 2021. The article focusses on the complexities involved in the reform, with particular attention to EU law. Certain fundamental aspects contained in the EU Minimum Taxation Directive (2022/2523) are examined in addressing whether or not Pillar Two is compatible with the European Legal Framework. Finally, the issue of the taxation of minority investments in MNE groups is examined in light of the subject-to-tax rule.