The landmark 2021 global tax deal is on its way to being implemented with at least the European Union set to apply the 15% global minimum tax next year, and a goal for governments to finish negotiations on the profit reallocation rules in the coming months.
But countries still face the big hurdle of a multilateral negotiation before they can finalize the text of a treaty implementing the reallocation rules, known as Pillar One. They’re still working through issues such as the treatment of withholding taxes and unilateral measures.
The minimum tax, known as Pillar Two, also requires more work ...
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