Pillar Two
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
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
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
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Sponsored by HLB ThailandPaul Ashburn and Anna Selina De Vera of HLB Thailand say the decree underlines the country’s commitment to pillar two implementation as Thailand aims to become one of the first two Southeast Asian countries to join the OECD -
Sponsored by VdATeresa Teixeira Mota and Francisco Lencastre Torres of Vieira de Almeida & Associados explain how generative AI and enhanced human understanding can help in-scope Portuguese constituent entities manage the complexities of pillar two compliance
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss the recently published Provisional Measure 1262/24 and Normative Instruction 2228/24 as a statement of Brazil's commitment to the OECD's global tax standards
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