The OECD BEPS 2.0 project is gaining steam. In December, the OECD released a public consultation document on tax certainty for the Global Anti-Base Erosion (GloBE) Rules under Pillar Two. Prior to this, in October, the OECD released a progress report on the administration and tax certainty aspects of Amount A under Pillar One.
Read the global comment letters that the EY organization submitted to the OECD on Amount A under Pillar One, and Pillar Two - Tax Certainty for the GloBE rules (pdf). These two documents highlight how these global tax rules need global tax certainty mechanisms. As governments around the world consider these proposals, it is important that clients keep up to date with these developments and consider the potential impact on their controversy strategy.
Additional information and links to past newsletters can be found in the attached PDF.
