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On 20 December 2022, the OECD/G20 GloBE Inclusive Framework released its Pillar Two Safe Harbour and Penalty Relief guidance document. Read an article about the key elements of the transitional and potential permanent safe harbours from our tax experts in Belgium.
New year, new legislation – which means that this year, just like at the beginning of every year, the focus is on changes to the tax rules. One of the most important changes affecting most Hungarian taxpayers in 2023 is the amendment of the transfer pricing documentation rules.
Read an article from GTM, U.S. alliance partner of WTS Global, on how to avoid pitfalls related to the consistency rule in the allocation and apportionment of deductions to the residual grouping in applying the GILTI high-tax exception.
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