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Pillar 2: What’s Ahead

The global minimum tax is turning out to be a huge compliance hurdle for many multinationals, especially those with widespread subsidiaries across the globe. Multinationals face new laws, guidance, and rules for collecting data.

While the Organization for Economic Cooperation and Development (OECD) provides a decent roadmap to help businesses navigate the tax—including the initial 70-page model rules, commentary on the intended outcomes of the rules, and three tranches of administrative guidance—compliance demands more than understanding these regulations. To pay their global minimum tax bill in a timely manner, large companies need to build new systems to synthesize thousands of pieces of new data and track the differences between countries’ local laws applying the levy.

This special report explores these challenges and the disputes that loom large under the new regime.

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