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Searching for Pillar Two clarity: The OECD’s Administrative Guidance

Cross-border Tax Talks

CHAPTER

Common Control for US Gap Payers

In years with foreign exchange volatility, frankly, any company that's close to 750 million and you know that particular that they're not in euro. You're obviously going to need to pay attention to just business and operational results, but also currency because that could certainly move the needle and take people potentially into scope. All right. Next one wanted to cover common control. So this is a topic that I think some of our US gap payers, taxpayers have been very interested in for the last year and a half. The guidance we got on this front is not too long. But effectively what it says is once the rules are applied, so once you're within the pillar to blow rules, three

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