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International Tax Bytes: 7 October 2022

ITB is a weekly PodCast by Steve Towers. It covers all major global tax events for any given week.

07 October 2022: This week’s highlights

  • Latest developments on Pillars One & Two
  • Progress report on administration and tax certainty aspects of Amount A in Pillar One
  • Report on tax incentives and GloBE rules
  • Belgium announces that it will proceed with implementation of GloBE rules, even without Hungary’s agreement
  • Interesting international tax cases and rulings
  • UK case on unilateral foreign tax credits
  • Spanish ruling on application of GAAR to chain of transactions
  • Continuation of detailed review of GloBE model rules
  • Today: paras. (f) to (h) in Art. 6.2.1, on Constituent Entities joining and leaving an MNE Group

Read the entire document here.