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Implications of Pillar 2 for multinational groups

12 February 2024 / Chris Danes , Steve Davies , Alex Lubbock
Issue: 4924 / Categories: Comment & Analysis , BEPS , multinationals , OECD , Compliance
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Multinational headache?

Now that Pillar 2 has come into effect what actually are UK multinational groups focused on as they navigate their way through these new rules including meeting the increased tax compliance burden?

Background

Over recent years some multinational enterprises (MNEs) have been able to exploit gaps and mismatches in the tax rules of different countries to avoid paying tax. These tax planning strategies are known as base erosion and profit shifting (BEPS).

To address these issues the Organisation for Economic Co-operation and Development (OECD) created a tax framework called BEPS (now referred to as BEPS 1.0) which was initially introduced by means of a 15-point action plan in 2015. As the global economy has become more and more digitalised MNEs have been able to access global markets with relative ease mitigating the effects of BEPS 1.0. To combat this the OECD has...

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