Germany Issues Draft Regulation Listing Jurisdictions With Qualifying Pillar Two Status
On April 8, 2026, Germany issued a Draft Regulation listing jurisdictions with qualifying status for the IIR, UTPR, QDMTT and QDMTT Safe Harbour, providing …
Pillar Two
Practical TP Issues
Practical TP Issues
Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance
On April 7, 2026, the Swiss Federal Tax Administration issued Communications 030-E-2026 and 031-E-2026, applying the OECD's January 2025 and January 2026 Pillar …
Industry Insights
OECD Inclusive Framework Agrees Side-by-Side Package on Pillar Two
The Inclusive Framework on BEPS reaches agreement on a Side-by-Side system that exempts US-headquartered MNE groups from certain Pillar Two top-up taxes for …
Transfer Pricing Basics
Transfer Pricing in the International Tax Architecture
Understand where transfer pricing sits within the broader international tax system: its interaction with CFC regimes, GILTI/NCTI, BEAT, Pillar Two, withholding …