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International review for October 2023

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.

BEPS 2.0 update

New MLC to implement Amount A of Pillar One

On 11 October 2023 the OECD released the text of a new multilateral convention (MLC) to implement Amount A of Pillar One. The MLC is accompanied by an explanatory statement (ES) providing clarification on how each provision is intended to apply. The ES is intended to form part of the context of the MLC to be used for interpretation purposes under international law. It is also accompanied by an Understanding on the application of certainty document which contains further details on how aspects of the Amount A tax certainty framework will operate in practice.

The MLC reflects the current consensus among members of the Inclusive Framework (IF). There are...

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