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Unpacking Pillar Two: US implementation

OECD, United Kingdom - May 9 2022 The Build Back Better Act, the US legislation that would bring its existing minimum tax rules in line with the OECD's BEPS 2.0 project, has stalled…

Sarah Ling, Bezhan Salehy

Unpacking Pillar Two: permanent establishments

OECD, United Kingdom - April 11 2022 Pillar Two of the of the OECD Inclusive Framework contains the rules to implement the global minimum tax. It does so by identifying jurisdictions in…

Unpacking Pillar Two: split ownership and Joint Ventures (JVs)

United Kingdom - February 21 2022 Many large groups will include entities that are not wholly owned. How the model rules treat split ownership is somewhat opaque: there are several…

Gregory Price, Bezhan Salehy, Rhiannon Kinghall Were

Limitation on Brexit: the UK, the EU, and US treaty benefits

European Union, United Kingdom - August 23 2021 A recent agreement between the UK and US competent authorities seeks to address the impact of Brexit on the UK/US double tax treaty, which has…

Lawrence Parkin, Rhiannon Kinghall Were

Reforming the international tax system: what you need to know

OECD, United Kingdom - July 23 2021 Similar to the June communique from G7 finance ministers endorsing the proposals in principle, this represented another important step towards a…

Gregory Price, Lucy Urwin, Rhiannon Kinghall Were