Peter Nias, barrister and Centre of Effective Dispute Resolution (CEDR) panel mediator of Pump Court Tax Chambers in the UK, considers whether the arbitration provisions in the OECD’s Multilateral Instrument (MLI) and Action 14 proposals offer the only option for dispute resolution for all parties.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort