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Tag: US

The End of OECD’s Pillar I and Pillar II?

The recently issued memorandum for the Secretary of the Treasury addressing the OECD Global Tax Deal signals a major shift in U.S. tax policy, with significant geopolitical implications. Here’s a quick breakdown of the key aspects: -No Binding Effect Without Congress: Commitments

Pillar One Amount B US Update

The IRS released Notice 2025-4 on December 18, 2024, announcing its intention to implement Amount B of Pillar One, thereby potentially simplifying how multinational companies calculate margins for certain “baseline” distribution activities. This “Simplified and Streamlined Approach” (SSA) is based on new

Intercompany Financing in Volatile Interest Rate Environments

Intercompany financial transactions are essential for multinational enterprises (MNEs) navigating the complexities of capital movement among subsidiaries. As interest rates fluctuate, MNEs should periodically evaluate their intercompany financing arrangements to ensure compliance with the arm’s length principle and optimize tax and cash

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