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UK, EU Must Grapple With Implications of OECD Side-by-Side Deal
The OECD’s new “side-by-side” deal exempts US-headquartered multinationals from much of its global minimum tax rules. The UK government has announced that it will implement this deal through new domestic legislation (retroactive to Jan. 1). The EU plans to implement it as well, likely through treating the new safe harbor as consistent with existing exemptions rather than trying to amend the Pillar Two directive that created the minimum tax regime.