DSTs in one form or another have been unilaterally enacted by around 15 jurisdictions, including Austria, France, Spain, Kenya, the UK, Italy, India, Tunisia and Turkey. There are some big differences among DSTs that have been enacted or proposed, in…
Two key general principles of the current international tax system are that: Firstrly, foreign companies don't become subject to a country’s corporate income tax until they have created a permanent establishment (PE) there; and Secondly, income…
Key Mechanisms The aim of the Pillar Two proposals is to ensure that MNEs pay a minimum level of tax regardless of where they are headquartered or the jurisdictions they operate in. It seeks to achieve this, broadly by the operation of two…