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Pillar Two: A Japanese perspective
Cross-border Tax Talks
The Complexity of QDMTT
The complexity is mind-dumbing. There's this tension here. Absolutely, and I think the challenge that taxpayers are going to have is, you know, there's kind of ... Most jurisdictions will implement QDMTT but when do they do it? And then now we've got,. you know, Japan with the April and just as different jurisdictions in Korea, which has said,you know, UTPR and IR1124. How this layers in with respect to foreign tax credits, particularly we have CFC regimes, will be very challenging for taxpayers just from a calculation perspective.
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