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President Trump’s ‘statement of intent’ rejecting Two-Pillar solution

Among the various ‘Presidential Actions’ released on 20 January 2025 shortly after President Trump’s inauguration the following are likely to be of interest to tax practitioners. 

The ‘OECD Global Tax Deal ’ memorandum sets out a number of points which appear to reject the two-pillar approach to taxation of the digital economy. The memo suggests that what it calls ‘the OECD Global Tax Deal’ ‘has no force or effect in the United States’ with the relevant US representatives to notify the OECD that ‘any commitments’ made by the Biden administration will have no effect in the US unless provisions are adopted by Congress. Section 2 of the memo appears wide-ranging looking at ‘whether any foreign countries are not in compliance with any tax treaty with the United States or have any tax rules in place or are likely to put tax rules in place...

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