Pillar Two: Side-by-Side issues, and the Belgian UTPR case
European scrutiny of the Side-by-Side Package continues, with critical reviews in the Netherlands and potential delays to DAC6 reportingrelief. As the legal challenge to Belgium’s UTPR proceeds, Pillar Two may survive, but look increasingly less like a single coordinated global minimum tax, and more like a collection of national rules.
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Digital Taxation: Where tax and trade collide
Fifteen months after the G7 promised a “constructive dialogue” on digital taxation, Europe is growing impatient and looking again at digital taxmeasures. The United States, meanwhile, is using trade agreements to address DSTs, while a new proposal in Congress would revive tax policy as another source of leverage.
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