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International review for July 2023

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

BEPS 2.0 outcome statement

On 12 July 2023 the OECD released an Outcome statement on the two-pillar solution to address the tax challenges arising from the digitalisation of the economy. The outcome statement describes the status of the OECD/G20 Inclusive Framework (IF) base erosion and profit shifting (BEPS) 2.0 project. Key points to note from the statement are as follows.

Amount A of Pillar One

The IF has delivered a text of the multilateral convention (MLC) to implement Amount A of Pillar One. A few jurisdictions have expressed concern on certain issues and efforts are underway to resolve these. Once resolved the text of the MLC will be published and will it be open for signature in the second half of 2023. The MLC should enter into force during 2025.

Readers may remember that IF members agreed to refrain from imposing...

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