Reacting to P2 side-by-side
Reactions to the Pillar Two side-by-side package continue to highlight growing concern around who actually qualifies for the new safe harbours and how unevenimplementation may be across jurisdictions. While the package avoids a disorderly Pillar Two breakdown, compliance burdens, data demands, and governance uncertainty remain firmly in place.
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PWC'S SIDE-BY-SIDE SAFE HARBOUR + UPE SAFE HARBOUR ALERT
https://www.pwc.com/gx/en/tax/newsletters/tax-policy-bulletin/assets/pwc-oecd-publishes-pillar-two-side-by-side-system.pdf
PWC'S SIMPLIFIED ETR SAFE HARBOUR ALERT
https://www.pwc.com/gx/en/tax/newsletters/tax-policy-bulletin/assets/pwc-pillar-two-simplified-etr-safe-harbour.pdf
PWC'S SUBSTANCE-BASED TAX INCENTIVE SAFE HARBOUR ALERT
https://www.pwc.com/gx/en/tax/newsletters/tax-policy-bulletin/assets/pwc-substance-based-tax-incentive-safe-harbour-pillar-two-groups.pdf
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OECD commentary regarding cross-border remote work is expected to yield more certainty and flexibility for companies; additional guidance on global mobility is expected this year.
IN THISEPISODE
Giorgia Maffini, Special Advisor on Tax Policy and Transfer Pricing, PwC UK
Will Morris, Global Tax Policy Leader, PwC
PWC'S TAX POLICY ALERT
https://www.pwc.com/gx/en/tax/newsletters/tax-policy-bulletin/assets/pwc-oecd-issues-2025-model-tax-convention-update.pdf
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