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BEPS 2.0: the two-pillar approach

Ian Zeider and Laura Hodgson (Travers Smith) provide a back to basics guide. 

With the arrival of the Biden administration in the US the OECD has finally made political progress with its two pillar corporate tax reform plan. Agreement was reached amongst the G7 in June 2021 and on 1 July the OECD /G20 Inclusive Framework on Base Erosion and Profit Shifting published a statement (the ‘July statement’) setting out the key components of each pillar.

The July statement envisages both pillars coming into effect in 2023 which given the size and complexity of the reforms is an ambitious timetable.

Although the July statement only provides the bare bones of the new regimes much of it looks consistent with the chunky reports on the pillar one and pillar two blueprints (‘the blueprints’) published by the OECD in October 2020 and so...

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