1. Carve-out of financial services from the scope of Amount A
According to the Report on the Pillar One Blueprint,[1] the proposed scope of Amount A is designed to capture multinational groups that…
A couple of days ago, in the last weekly session of the Indiana-Leeds Summer Tax Workshop, I attended the presentation of a fascinating paper by Steven A. Dean (A Constitutional Moment in Cross…
Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…
1. Purpose of the blog
This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE…
1. Purpose of the contribution
The purpose of this contribution is to address the impact of the Pillar I debate on principal structures or centralized business models. The tentative assessment will…
