The OECD has set out its 2026 workplan, with further Pillar Two guidance, evolving safe harbours, and new coordination tools ahead. Countries are beginning to incorporate elements of the Side-by-SidePackage into domestic law. And, as UN Framework Tax Convention negotiations continue, new analysis is sharpening the debate on the economic tradeoffs of gross basis withholding taxes on cross border services.
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With key UN meetings approaching in early February, recent releases have clarified the direction of the proposed UN Framework Tax Convention and its protocols on cross border services and tax disputeprevention and resolution. The UN process has advanced further than many expected, with innovative approaches emerging that are likely to shape the international tax landscape.
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