Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.
European summer might well be in full swing but that has not stopped the OECD from pushing ahead with the implementation of its Two-Pillar reforms to international taxation. On 17 July 2023 the OECD published some 300 pages of new pillars-related guidance and consultation namely:
new ‘Agreed Administrative Guidance‘ on Pillar Two;
a report on the Pillar Two ‘GloBE information return’ (the GIR);
a report on the subject to tax rule (the STTR) including model provisions and accompanying commentary; and
a consultation document on ‘Amount B’ of Pillar One.
In this article we summarise the key developments and updates coming out of these new materials. The latest flurry of content from the OECD follows hot on the heels of the publication on 11 July ...
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Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.
European summer might well be in full swing but that has not stopped the OECD from pushing ahead with the implementation of its Two-Pillar reforms to international taxation. On 17 July 2023 the OECD published some 300 pages of new pillars-related guidance and consultation namely:
new ‘Agreed Administrative Guidance‘ on Pillar Two;
a report on the Pillar Two ‘GloBE information return’ (the GIR);
a report on the subject to tax rule (the STTR) including model provisions and accompanying commentary; and
a consultation document on ‘Amount B’ of Pillar One.
In this article we summarise the key developments and updates coming out of these new materials. The latest flurry of content from the OECD follows hot on the heels of the publication on 11 July ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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