The Inclusive Framework has just released Administrative Guidance with respect to the GloBE Rules (Pillar 2). The AG includes rules to prevent the use of Hybrid Arbitrage Arrangements to artificially qualify for the Transitional CbCR Safe Harbour.
 
(oecd.org).

Letter to the Editor: Heydon Wardell-Burrus explains how the essence of the UTPR is broad recognition by a critical mass of states in the international community through their lawmaking institutions. taxnotes.co/3BVbZrE

Up to date and in depth analysis of the OECD’s Two Pillar Solution proposals from leading experts with editorial by John Vella - US perspective from MindyHerzfeld; EU (Ana Paula Dourado); Bezan Salehy; Heydon Wardell-Burrus ; Chris Noonan and Victoria Plekhanova. On Westlaw now.

Do we need a tax google sheet?
I'm @[email protected]
Dan Neidle (free-riding on the economists, which may prove wise) is [email protected]
Others, post your handle in response until someone more organized takes over.

The OMG Transatlantic Tax Talks will continue, starting next week on Thursday 20 October at 17:00 (12:00 EST/6:00 CET). Attendance is free and no registration is required. Visit the CBT website for full details oxfordtax.sbs.ox.ac.uk/omg-seminar-se…