Johanna Hey

Prof. Dr. Johanna Hey has been Director of the Institute for Tax Law at the University of Cologne since 2006 and Vice Dean for International Affairs since 2024. From 2002 to 2006, she held the Chair of Corporate Tax Law at the University of Düsseldorf. From 2010 to 2021, she was Academic Director of the Institute for Finance and Taxation. Johanna Hey is Chairwoman of the German Tax Law Association since 2023 and has been a member of the Academic Advisory Board of the Federal Ministry of Finance since 2006. She is also responsible editor of the legal commentary on tax law Herrmann/Heuer/Raupach and managing editor of the interdisciplinary journal Steuer und Wirtschaft. She is member of the editorial board of intertax, and also co-editor of the journals Der Betrieb, and Zeitschrift für internationales Steuerrecht. Johanna Hey was Global Professor at New York University School of Law in 2015 and Senior Emile Noel Fellow in 2007 and 2018 and received the Future Prize of the University of Cologne (Hans Kelsen Prize) in 2016.

Her research focuses on: Constitutional and European law foundations of tax law, income and corporate tax law, international tax law.

Contact: jh170@nyu.edu

Research Project

Tax Multilateralism and national tax legislation. Taxes play a central role in economic competition between countries. On the one hand, low taxes attract investment as well as labor, while on the other hand, high tax revenues enable the state to act effectively. The taxing countries face a common challenge in capturing mobile sources of tax revenue, particularly corporate profits. This is why the international community launched the initiative against base erosion and profit shifting (BEPS) in 2012 and has since been working multilaterally to safeguard corporate tax revenues by limiting tax competition and combating tax avoidance. In 2021, nearly 140 countries agreed, within the Inclusive Framework, on the so-called Two-Pillar model, which includes Pillar One for the global redistribution of tax revenues and Pillar Two for the global minimum tax. After the United States withdrew from the Global Tax Deal in 2025, the question came up what multilateralism can realistically achieve in tax law and how the work should proceed. Although the OECD was able to resolve the conflict with the United States in early 2026, little remains of the original concept of the global minimum tax, and further changes of the OECD model rules have been announced. For the countries participating in the Inclusive Framework this poses the challenge of continuously adapting the national tax law. For future efforts by international organizations (OECD/UN) to coordinate the further development of international tax law, the question arises regarding the objectives and instruments for influencing the tax policies of sovereign states. Despite the considerable effort invested in developing the model rules for the global minimum tax, there has been no significant discussion of the instruments available to achieve the objectives of a new global tax order. The validity of the multilateral agreements, their necessary scope, and the importance of their uniform implementation are all crucial considerations.