The PILITY Model Rules and Commentary

The most common scenario where we see that is where a company does an acquisition and then they have an intellectual property strategy. Even if you've paid full-boat tax in Spain on that IP transfer, the step up you get for US purposes is not really respected for Pillar 2 because this was an internal asset transfer. So obviously the rules were designed to rent companies taking IP from a low-tax jurisdiction or not paying tax of trying to get a step up. And that obviously in the situation that we're discussing is not the case. The discussions that we've had with the UK for them to go and discuss at the OECD level is whether we can extend that reorganization relief to pick up those