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International review for March 2022

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On 14 March 2022 the OECD released its much-anticipated commentary on the BEPS pillar two model rules. Countries continue to plan their response to the global minimum tax regime under pillar two with Singapore and Hong Kong announcing the introduction of domestic top-up tax regimes. As part of its broader tax review Guernsey will commission independent analysis of its corporation tax regime which will take into account developments on the global minimum tax rate. Work on BEPS pillar one continues with the OECD launching and closing two public consultations within short timeframes. The timing and content of further ‘rolling consultations’ on pillar one remains uncertain. Australia has introduced a Bill for a new patent box regime for medical innovations. At the time of writing the misuse of shell entities for tax purposes (ATAD 3) consultation response deadline is fast approaching and potentially affected groups...

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