Summary
While the U.S. has pulled out from the Global Tax Deal early 2025, threatening taking countermeasures, the latest batch of Inclusive Framework (IF) documents state several times that the IF…
The Pillar 2 initiative (GloBE and QDMTT) has been seen as the end of using low effective corporate income tax rates (either by virtue of low nominal corporate income tax rates and/or through the use…
1. Background
1.1 An overview of current tax proposals
The Omnibus Bill (Ley de Bases y Puntos de Partida para la Libertad de los Argentinos, the Bill) is a multi-purpose, comprehensive legislative…
Introduction
In Fall 2021, almost 140 members of the Organisation for Economic Cooperation and Development (OECD) / Group of Twenty (G20) Inclusive Framework (IF) on Base Erosion and Profit Shifting …
The GloBE Model Rules have introduced the Qualified Domestic Minimum Top-Up Tax (QDMTT) into the ruleset of the international compromise on an effective minimum tax (“Pillar 2”). A QDMTT is defined…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Tsilly Dagan, GLoBE: The Potential Costs of Cooperation
This article argues…
Some OECD officials have reportedly noted that countries should consider changing or eliminating potentially duplicative anti-avoidance measures, such as CFC legislation when they implement the 15%…
By Jefferson VanderWolk
Partner, Squire Patton Boggs[1]
The GloBE Model Rules were issued in final form in December 2021. No public consultation was undertaken regarding any draft Model Rules, as…
1. The IIR and the top-down approach
It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a…
