Searching for Pillar Two clarity: The OECD’s Administrative Guidance
Cross-border Tax Talks
The QDMTT and the 750 Million Euro Threshold
QDMTT is not required to have a substance-based carve out or debinnomous income exception like we see with respect to country by country report for the model rules. If it does, it cannot be more expansive than those exceptions permitted under the globe rules. QDMTT was not a part of the EU directive and so I do have some just kind of practical questions with respect to how the EU is going to implement it.
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