3min chapter

Cross-border Tax Talks cover image

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

Cross-border Tax Talks

CHAPTER

The Importance of Variation in Design in Taxation

I think there's going to be several scenarios where you end up with maybe not double taxation in the pure sense, but certainly additional taxation for one another. And I'm going to quote here because it said that some degree of customization of a QDMTT in each jurisdiction is to be expected. It goes on to say that variations and outcomes between the minimum tax and global rules will not prevent that tax from being treated as a QD MTT if those variations systematically produce a greater incremental tax liability. Is there any thoughts or is there any clarity on what that means? The short answer is no, there is no clarity,. But I would say I would suspect they meant it with respect to

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