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Pillar Two Update: Traps for the unwary

Cross-border Tax Talks

CHAPTER

Navigating OECD Tax Guidance and Incentives

This chapter explores the evolving OECD guidance on tax credits and incentives under the Pillar 2 regulations, focusing on the complexities of refundable and non-refundable tax credits. It highlights the implications for U.S. R&D credits and the challenges of adhering to new income inclusion rules and the Qualified Domestic Minimum Top-Up Tax (QDMTT). The discussion emphasizes the need for clarity amidst ongoing international negotiations and the uncertainties surrounding tax rule implementations.

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