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- Title
Pillar Two: Transitional CbCR Safe Harbour and the Qualified Country-by-Country Report.
- Authors
Carawan III, Harry B.
- Abstract
The article delves into Pillar Two of the OECD's (Organisation for Economic Co-operation & Development) Two-Pillar Solution, focusing on the Transitional Country-by-Country Report (CbCR) Safe Harbour and the concept of Qualified Country-by-Country Reports. It examines the requirements for a report to be considered as a Qualified CbCR, addressing issues such as stateless entities, minority interests, intragroup dividends, joint ventures, and hybrid arbitrage arrangements.
- Subjects
ORGANISATION for Economic Co-operation &; Development; SAFE harbor; JOINT ventures; DIVIDENDS; ARBITRAGE
- Publication
International Tax Journal, 2024, Vol 50, Issue 1, p20
- ISSN
0097-7314
- Publication type
Article