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New Pillar Two Guidance: Practical Impact on MNEs with U.S. Operations

CPE 1.5


Event overview

A report released by the Organisation for Economic Co-operation and Development (OECD) on July 17 included a package of new Pillar Two documents on the global anti-base erosion (GloBE) Information Return (GIR), further administrative guidance on the GloBE Model Rules including two new safe harbors, and the subject to tax rule (STTR) to be incorporated into bilateral treaties.

KPMG LLP is pleased to invite you to a 90-minute webcast that will examine this latest round of guidance and its potential impact on multinational enterprises (MNEs) with operations in the United States. Professionals from the International Tax and Transfer Pricing groups in the KPMG Washington National Tax practice will discuss practical insights on:

  • The current state of Pillar Two legislative developments in key jurisdictions
  • What comprises the latest OECD guidance and what may be coming next
  • The transitional undertaxed profits rule (UTPR) safe harbor
  • Guidance on the treatment of tax credits
  • The safe harbor for jurisdictions that introduce a qualified domestic minimum top-up tax (QDMTT)
  • Additional administrative guidance on currency conversion rules and the substance-based income exclusion
  • The GIR and the sharing of information with implementing jurisdictions
  • The STTR provision

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