PILLAR-TWO

Tim Sarson

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.

Tamar Ruiz

Matthew Mortimer

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.

David Goldberg QC

Constantine Christofi

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).

Tim Sarson

This month’s update from Tim Sarson (KPMG).

James Burton Brin Rajathurai Mitchell Fraser

Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.

Bezhan Salehy

Sarah Ling

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.

Tim Sarson

Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).

Rhiannon Kinghall Were

Ashley Greenbank

While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).

Chris Sanger

Jack Gifford

The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and Jack Gifford (EY).

Tim Sarson

Pillar Two implementation is gaining traction around the world, reports Tim Sarson (KPMG).

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