BEPS

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.

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

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).

Heather Self (Blick Rothenberg) pays tribute to the former OECD tax director – a formidable driving force in reforming international tax policy.

Laura Hodgson, Elena Rowlands and Jessica Kemp (Travers Smith) analyse the UK’s draft multinational top-up tax legislation and consider what developments are still to come.

Bezhan Salehy (Macfarlanes) considers how countries may maintain their tax competitive standing after the implementation of pillar two.

Brin Rajathurai and May Smith (Freshfields Bruckhaus Deringer) explain how pillar two will have an uneven impact on the attractiveness of different target companies and potentially favour certain types of bidders over others.

Laura Hodgson (Travers Smith) explains why the proposed new rules may require businesses to bolster the substance of their EU holding companies.