BEPS 2.0 Pillar Two: how to navigate uncharted tax waters
Recent policy statements from the US and the G7 introduced the concept of a side-by-side system, which is intended to exempt US-parented groups and their foreign subsidiaries from the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR). This has fundamentally changed the trajectory of the OECD Pillar Two project and raised many questions such...

