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UK Updates: Pillar Two is Coming

Cross-border Tax Talks

CHAPTER

Is the OECD Going to Revise the Initial Model Rules and Commentary?

The UK government will actually meet with advisors and taxpayers. If the UK starts to tweak these rules too much, there's the risk that it's no longer a qualifying income-inclusion rule or CUDIA or qualified domestic minimum tax. The OECD just does not appear to be a very big appetite from the OECD to really go back and revise the initial model rules and commentary. But I say improvements really to clarifications because this is solely highly complex.

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