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UK Updates: Pillar Two is Coming

Cross-border Tax Talks

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What's the Pope Doing in Pillar 2?

There's no mechanism for taxpayers to go back and kind of refund that top-up tax if there had been a similar type of transfer pricing adjustment. If you've got a JV with a minority shareholder with 20% or more interest then you're a pope. So what's the pope doing in Pillar 2? It's a good question. The mediation partially owned parent entity is paid by the joint venture holding company, the taxes at that level. But as we know when you calculate the top tax it's a jurisdictional blending basis based on all the entities in the group. And so I think that we're also hoping maybe for and maybe the UK will leave the charge on this or working

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