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Threading the Needle: Pillar Two and the IRA’s Green Energy Credits
Cross-border Tax Talks
The OECD's Guidance on Transferable Credits
The OECD issued its first round of administrative guidance on Pillar 2 as additions to the model rules and commentary. The US Treasury Department immediately came out with a statement that said, and I'm going to quote Pat, that the package of guidance provides certainty on several key issues. It does not provide any relief for transferable credits. So the best you can say about transferable credits is we kind of don't know, but that in and of itself may be too optimistic of an assessment.
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