OECD releases September Pillar Two package
The OECD’s September 11 Pillar Two package introduces guidance under which certain “explicitly conditional taxes” that are actually paid may not counttoward the 15% minimum. The revised GIR incorporates Side-by-Side, but another XML transition is expected, and the same GIR information may still have to be filed by SbS taxpayers, so some, but certainly not dramatic, relief.
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LINK TO PWC'S TAX POLICY ALERT
https://www.pwc.com/gx/en/tax/newsletters/tax-policy-bulletin/assets/pwc-oecd-inclusive-framework-pillar-two-package-addresses-consistency.pdf
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Developing countries, tax incentives, and P2
Peru’s proposed economic zones neatly illustrate a broader problem for tax incentives under Pillar Two. As the rules change the economics of thoseincentives, developing countries will likely find themselves with even fewer tools to compete with richer countries for investment.
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