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Pillar Two Update: Traps for the unwary

Cross-border Tax Talks

CHAPTER

Navigating Country-by-Country Reporting Challenges

This chapter explores the complexities of Country-by-Country Reporting (CBCR) safe harbors, detailing the implications of recent administrative guidance on compliance and adjustments. It emphasizes the importance of accurate legal entity level data and the challenges posed by hybrid arbitrage and income inclusion rules for U.S. multinationals. Additionally, the discussion shifts to the integration of local statutory financials in CBCR reporting and the wider effects of global tax policies on corporate tax incentives.

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