GloBE CbCR Safeharbour

2 articles available

This piece examines the CFC carve-out in the reportedly leaked EU Tax Omnibus proposal and argues that, rather than simply reducing overlap with Pillar Two, it introduces a layered exemption that…

Issues involving controversy surrounding the operation of the newly devised Pillar Two rules in company taxation seem to have moved strikingly up business agendas and political agendas recently…