Large multinational enterprises (MNEs) should review the Organization for Economic Cooperation and Development’s (OECD) latest publications related to its two-pillar approach to address tax challenges from the digitalization of the economy. In an update to its work on Pillar One, the OECD advises that it is proceeding with work on the Multilateral Convention (MLC) to implement “Amount A” and is seeking further feedback on the design of “Amount B”. In addition, the OECD has released a model provision and commentary for the Subject to Tax Rule (STTR) under Pillar Two, a standard template for the “global anti-base erosion” (GloBE) Information Return and related administrative guidance, including two new safe harbours.
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