Module VI·Article III·~1 min read
International Taxation
Taxation
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International Taxation
International taxation FATCA (Foreign Account Tax Compliance Act) of the USA requires banks to report on accounts of Americans CRS (Common Reporting Standard) 140+ countries exchange information about accounts of non-residents OECD BEPS (Base Erosion and Profit Shifting) rules against profit shifting to preferential jurisdictions Economic substance regulations requirement to have real activity, not just tax benefit UBO (Ultimate Beneficial Owner) disclosure disclosure of the ultimate owner (the regulator must know) Pillar One / Pillar Two (Global minimum tax 15%) global minimum tax for large companies PE attribution rules when the presence of people in a country creates a PE (taxes must be paid) MLI (Multilateral Instrument) instrument for the rapid implementation of tax treaties
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