PILLAR-TWO

OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG). 

Tim Sarson (KPMG) reports on a busy start to what promises to be an eventful year for the international tax world.

Timing differences could affect a group’s effective tax rate as much as permanent differences do, writes Bezhan Salehy (Macfarlanes).

Jonathan Hare, Giorgia Maffini and Phil Greenfield (PwC) examine the OECD’s model rules for pillar two. 

John Havard and Heather Self (Blick Rothenberg) discuss the current US position on the OECD’s two pillar tax deal.

Progress on BEPS 2.0, the EU’s public CBCR directive and plans for a new EU withholding tax system are among recent developments examined by Tim Sarson (KPMG).

Ian Zeider and Laura Hodgson (Travers Smith) provide a back to basics guide. 

The recent international agreement on the OECD’s two-pillar approach is intended to take unilateral digital tax measures off the table and put an end to these trade wars. But that does not necessarily mean there is no further role for trade law in this area, write Brin Rajathurai and Lorand Bartels (Freshfields Bruckhaus Deringer).