As previously reported, the OECD has issued Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two). One of the key aspects of the administrative guidance is the inclusion of two safe harbours, the QDMTT Safe Harbour and the Transitional UTPR Safe Harbour. These safe harbours are summarized in the guidance as follows:

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5.1 QDMTT Safe Harbour

Introduction

1. A …

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