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Mounia Benabdallah, Baker McKenzie Partner and Member of the Global Pillar Two Steering Committee, recently spoke with Tax Notes about the unclear outlook for the OECD’s Pillar Two tax reform measures in the coming year.
With several jurisdictions now enforcing the undertaxed profits rule (UTPR), Mounia commented on the legal complexity and practical issues that arise from the spotty implementation of these measures. Reflecting on the year ahead, she also noted that top priorities for 2025 include the OECD’s anticipated guidance on permanent safe harbors as well as dispute prevention and resolution under the GloBE rules. Ultimately, she noted, taxpayers are facing “a lot of noise and uncertainty.”
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