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OECD Publishes Pillar Two Global Minimum Tax Safe Harbor, Benefitting MNE Groups With Ultimate Parent Entities Located in the U.S.

On January 5, 2026, the Organisation for Economic Co-operation and Development (OECD) released a long-awaited package of administrative guidance which introduces a number of new safe harbors within the Pillar Two Global...more

New CRS Regulations – What UK Investment Managers Need To Know

Updated regulation: On 25 June 2025, HMRC issued the International Tax Compliance (Amendment) Regulations 2025 (the 2025 Regulations) amending the existing International Tax Compliance Regulations 2015, introducing...more

UK Government Targets Reform of the Investment Manager Exemption

On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more

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