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Pascal Saint-Amans: The Pillar Two Origin Story
Cross-border Tax Talks
The Impact of the UTPR on the Global Treaty Network
There's been a lot of discussion and debate amongst academics, particularly from a US perspective as the US thinks about potential implications of their tax base. And I do think that the underlying architecture that significantly changed when they went from the payments to the profit. The analysis made by the OECD Secretaries was the governments was that they can move ahead. It's compatible with treaties. But this was decided by governance. So we'll see what courts decide.
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