The G20 Finance Ministers and Central Bank Governors issued a Communiqué yesterday which among other things, and not surprisingly, heralds "a historic agreement on a more stable and fairer international tax architecture" and "endorse[s] the key components of the two pillars on the reallocation of profits of multinational enterprises and an effective global minimum […]
Monthly Archives: July 2021
Reflecting on the OECD’s July 1 “Two-Pillar Plan” Announcement
“Coming Soon”? It is possible to be hopeful and constructively critical of the OECD’s Two-Pillars strategy that flows out of the BEPS project, most recently advanced in the OECD’s July 1 announcement now a feature component of the July 2021 OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors for their […]
A Couple of More Thoughts on “Hiding in Plain Sight? Changes to “Transfer Pricing” and the GAAR"
I do not know what “good form” is for commenting on one’s own blog post. But it does strike me that some elaboration may be helpful on the suggestion in that blog, to infuse the Canadian GAAR (and its sentiments applied in transfer pricing) with a statutory reflection of the United Kingdom GAAR’s explicit […]