The US Treasury has published its final regulations denying US treaty benefits to payments made through so-called hybrid entities. The regulations’ limited scope means they only deny treaty benefits that might otherwise be available. By Kim Blanchard of Torys, New York
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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.