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International: OECD IF delivers latest set of updates and guidance

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In brief

On 17 July 2023, the OECD/G20 Inclusive Framework on BEPS released a package of documents as part of its continuing effort to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy. On Pillar Two, this included further Administrative Guidance (including two new safe harbours) and the GLoBE Information Return, together with a report on the Subject to Tax Rule including a model treaty provision and accompanying commentary. We set out below our experts’ insights on these publications.

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Mounia Benabdallah is a principal in Baker McKenzie’s International Tax Practice Group. She joined Baker McKenzie in 2006 and has practiced in the Firm’s offices in Amsterdam, Chicago and New York. As an attorney at law she is admitted to the Netherlands Bar. Mounia is repeatedly recognized as leading advisor in ITR’s Women in Tax Leaders guide. Because of her strong US focus, Mounia is based in New York and member of the Global Reorganizations Practice Group. Mounia mainly advises US multinationals on the interplay between US international tax law, European tax law and Netherlands tax law in global restructuring projects, with a strong focus on global (OECD BEPS) and European tax policy developments.

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Miles Humphrey is an International Principal Tax Advisor in Baker McKenzie's North America and EMEA Tax Practice Groups. Miles uses his deep knowledge of international aspects of US tax law and the interactions with UK/European tax law to act as a bridge between the UK and US to develop innovative tax planning solutions, often in response to tax law changes. Prior to joining the Firm, Miles served as the ICE Tax Desk Leader at Deloitte where he advised clients across several industries, with a particular focus on tax efficient financing and holding company structures; the ownership of IP; the location of treasury; risk and credit functions; the tax implications of restructuring; relocations and reorganizations and various treaty issues.

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Nick Evans is a senior tax adviser in Baker McKenzie London office.

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Narine Movsisian is a senior associate in Baker McKenzie's Tax Practice Group.

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Ed Swift is a Senior Associate in Baker McKenzie London office.

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Pablo Fernandez is an Associate in baker McKenzie, Barcelona office.

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