Introduction

As of 9 July 2021, 132 countries and jurisdictions, representing more than 90 per cent of global GDP, have signed up to the Organisation for Economic Co-operation and Development’s (OECD) Inclusive Framework for international tax reform and a global minimum rate of corporation tax.

On 12 October 2020, the OECD published its Blueprint for the Inclusive Framework on Base Erosion and Profit Shifting (the Inclusive Framework). The Inclusive Framework proposals are targeted at reducing the use of low tax rate jurisdictions by large Multinational Enterprises (MNEs) in order to lower their global tax liabilities. A key part of the OECD’s proposals for achieving this objective is the introduc...

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