James Burton, Ellen Birkemeyer, Naomi Lawton and Mitchell Fraser (Allen & Overy) provide a 20 questions guide.
1. What is Pillar Two? How and why did we get here?
It has been something of a long and meandering journey but the origins of Pillar Two and the global anti-base erosion (GloBE) rules can be traced back to the OECD’s base erosion and profit shifting (BEPS) project which began in 2013 with the publication of Addressing Base Erosion and Profit Shifting. In this report the OECD considered the use by multinational enterprises (MNEs) of legal constructs to shift profits cross-border away from jurisdictions in which economic activities took place or value was created (typically higher tax jurisdictions) and into lower tax jurisdictions.
The report led to a number of further proposals for action the first of which looked to address the tax challenges...
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James Burton, Ellen Birkemeyer, Naomi Lawton and Mitchell Fraser (Allen & Overy) provide a 20 questions guide.
1. What is Pillar Two? How and why did we get here?
It has been something of a long and meandering journey but the origins of Pillar Two and the global anti-base erosion (GloBE) rules can be traced back to the OECD’s base erosion and profit shifting (BEPS) project which began in 2013 with the publication of Addressing Base Erosion and Profit Shifting. In this report the OECD considered the use by multinational enterprises (MNEs) of legal constructs to shift profits cross-border away from jurisdictions in which economic activities took place or value was created (typically higher tax jurisdictions) and into lower tax jurisdictions.
The report led to a number of further proposals for action the first of which looked to address the tax challenges...
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:
