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International review for January 2022

Speed read
It has been a busy start to what promises to be an eventful 2022 in the international tax world. The long-awaited BEPS 2.0 pillar two model rules were published on 20 December 2021, with some significant differences to the October 2020 blueprint. Despite this key development, much uncertainty remains, making the 2023 implementation deadline a challenge for governments and businesses alike. Whilst the EU has published a draft Directive to incorporate the pillar two rules into EU law, and the UK has launched a consultation on implementation, the current gridlock around the passage of the Build Back Better Act in the United States could have wider implications for the success of the BEPS project. Finally, EU public country by country reporting is progressing, further complicating an already challenging tax landscape for MNEs.

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