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Pillar Two: how safe is the safe harbor?

Cross-border Tax Talks

CHAPTER

Navigating Tax Regulations and Purchase Price Adjustments

This chapter provides detailed insights into recent administrative guidance on tax regulations, emphasizing the importance of understanding the transitional safe harbor rules. It focuses on purchase price accounting adjustments, CBCUR reports, and the impact on local jurisdiction's book income. Additionally, it discusses handling transfer pricing adjustments, the use of financial statements for pillar two compliance, and criteria for meeting CBCR safe harbor through the routine profits test.

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