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The Pillar Two GloBE Rules & Insurance Companies

There is no specific exemption for insurance companies under the Pillar Two GloBE Rules which may not reflect the relevant domestic tax treatment (eg Article 5 of the Dutch Corporate Income Tax Act exempts certain healthcare insurance companies from corporate income tax). Nevertheless, the GloBE rules do include a number of insurance specific adjustments. 

In this article we look at the nature of these provisions as well as the impact of the GloBE rules on insurance companies generally. 

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