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Searching for Pillar Two clarity: The OECD’s Administrative Guidance
Cross-border Tax Talks
Excluded Dividends in the US
Included dividends, as we understand this provision made its way into the admin guidance because certain taxpayers were maybe trying to exploit the treatment of dividends versus interest. So they effectively shut down that treatment and otherwise I think they caught it like a hyping or mechanism to increase the ETR in that place. And once the rules come online, we'll have a similar result for US gap as we do for IAP. The last one wanted to touch on was debt releases or a week commonly referred to in the US as cancellation on a debt and this income about debt release.
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