One cross-border tax attorney sees the Organization for Economic Cooperation and Development’s (OECD) new side-by-side safe harbor as patchwork relief for U.S.-parented multinationals, given its non-binding nature and the continued exposure to local top-up taxes.
Instead of a clean exemption from the OECD ‘Pillar Two’ 15% global minimum tax adopted by 140 other counties, the framework leaves U.S. companies facing ongoing compliance challenges, according to Robert Christoffel, counsel at Saul Ewing.
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