A single European market in the area of taxation still does not exist. In practice, this means that multinational corporations doing business in the EU need to navigate their way through (up to) 27 different national tax administrations and administrative requirements, and widely differing national interpretations of EU tax law, directives and regulations.
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The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions