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PILLAR-TWO


Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
The international tax world is still dominated by BEPS 2.0 developments, reports Tim Sarson (KPMG). This article includes an update on the national implementation of Pillar Two.
This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.
The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
This month’s update from Tim Sarson (KPMG).
Card image Brin Rajathurai James Burton Mitchell Fraser
Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).
While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).
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