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The two-pillar framework: what does the October statement tell us?

On 8 October 2021 136 out of the 140 countries of the OECD Inclusive Framework on Base Erosion and Profit Shifting (IF) have politically committed to potentially fundamental changes to the international corporate tax system. The group of 136 includes some countries that had previously expressed reservations about the deal in July such as Ireland Hungary Estonia Barbados and Peru but have now committed to the agreement. Pakistan which had signed up to the agreement in July has now withdrawn its support for the agreement. The agreement allows for some optionality in terms of implementation of both constituent pillars.

Three other countries of the IF membership have not signed up to the agreement yet: Nigeria (the largest economy in Africa) Kenya (the fifth largest economy in Africa) and Sri Lanka. Cyprus the only country in the EU 27) that...

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