The Second Set of OECD Administrative Guidance includes a number of additions to the design features of a QDMTT. Read more in this article.
The OECD Administrative Guidance included a number of new elections available to MNEs to simplify or minimise some of the adverse impacts of the GloBE Rules. We have updated our Pillar Two Elections product to include all GloBE Elections.
Deemed Disposal of Assets In some jurisdictions there can be a deemed disposal of assets. This occurs in the UK for instance where a company
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