The OECD’s work on base erosion and profit shifting (BEPS) is in the spotlight of worldwide taxation. Based on the Action Plan from last July and on two other reports – one published in March 2012 entitled Hybrid Mismatch Arrangements: Tax Policy and Compliance Issues and the other in February 2013 entitled Addressing Base Erosion and Profit Shifting – the OECD is clearly emphasising the need for action on this issue.
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The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
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