On 11 December 2023, Treasury and the IRS issued Notice 2023-80 (the “Notice”), which represents the US government’s first attempt to address the US federal income tax implications of Pillar Two. The Notice provides guidance on certain foreign tax credit and dual consolidated loss issues that arise in the context of Pillar Two. The Notice also extends the period of relief for the 2021 final foreign tax credit regulations until more guidance is issued.

On 31 March 2023, the Australian government released draft legislation and an explanatory memorandum regarding a new anti-avoidance measure, which prevents large multinational enterprises from claiming tax deductions for payments relating to intangibles “connected with low corporate tax jurisdictions.”