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Searching for Pillar Two clarity: The OECD’s Administrative Guidance

Cross-border Tax Talks

CHAPTER

The Importance of Transition Period Transactions

Two of the most common provisions mentioned are related to loss making jurisdictions and transition period transactions, 9.1.3 which has gotten a lot of discussion. So we got at least an answer on that still a lot of others. Which I think is a helpful answer for many taxpayers, albeit a lot of our bigger multinationals that are heavy and R&E and some of the other credits are kind of sitting waiting for maybe some additional. And hopefully we get some more guidance on that.

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