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Searching for Pillar Two clarity: The OECD’s Administrative Guidance
Cross-border Tax Talks
The OECD's Guidance on Tax Equity Structures
The OECD had a challenging task of trying to figure out an equitable way to do that. It didn't really seem to mention much on what was defined, how we define qualified refund tax credit. There's some relief which I think we'll get into in a minute with certain tax equity structures,. But generally, yeah, no relief for those credits that we can find in the package.
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