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2min chapter
Pascal Saint-Amans: The Pillar Two Origin Story
Cross-border Tax Talks
The Under-Tax Payment Rule
The UTP is quite different from what the US did, which was the beat. The idea is to cover all types of payment in bond as well as outbound. PILOT2 doesn't require that Cayman Island or the Bahamas or China or the US would implement for it to have an impact. And this was designed before the QDMTT came on top of that.
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