Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere.
On 20 January, President Trump...more
Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more
The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more
Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size.
The reforms reflect the outcome of an...more
European summer might well be in full swing, but that has not stopped the OECD from pushing ahead with the implementation of its Two-Pillar reforms to international taxation. (For further background on the two Pillars, see...more
The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more
The recent OECD report “Joining Forces for Gender Equality: What is Holding us Back?” (the OECD report) considered international progress on gender equality in a wide-array of policy areas from education and employment to...more
Across the world, governments are increasingly focusing on using tax measures to address ESG issues. In the UK, whilst it may not have been front and centre of the Chancellor’s speech on Budget Day, you don’t have to look too...more