Pillar Two: how safe is the safe harbor?
Cross-border Tax Talks
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Understanding Hybrid Arbitrage Arrangements and CFC Tax Allocation
The chapter explores the intricacies of hybrid arbitrage arrangements and the allocation of CFC taxes under the OECD's Pillar Two rules. It covers various types of hybrid arrangements like deductions without inclusions and duplicate loss situations, discussing concerns around potential exploitation by taxpayers. Additionally, the discussion delves into the implications of these rules for taxpayers, emphasizing the need for thorough compliance and potential pitfalls to avoid.
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