On 20 December 2021, the OECD released its Pillar Two model rules, also referred to as the “Anti Global Base Erosion” or “GloBE” rules, for participant jurisdictions to implement most of the Pillar Two rules. These rules seek enforcing a minimum 15% effective tax rate on profits earned by large multinational enterprises in each jurisdiction where they realise profits. The entry into force is targeted for 2023. The publication of the GloBE rules lifts the veil on a range of...

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The leaders of the EU, of the EU member states and of the Eastern Partnership countries met for the sixth Eastern Partnership summit in Brussels on Wednesday. The eastern partners present at the summit were Armenia, Azerbaijan, Georgia, the Republic of Moldova and Ukraine. The leaders emphasised their joint determination to uphold the fundamental values they share, such as strengthening democracy and the rule of la and protecting human rights and fundamental freedoms, including the rights of persons belonging to minorities. Tensions with Russia loomed large however as Ukrainian President Volodymyr Zelenskiy urged...

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Following up on a mandatory 2019 request for information issued by the Federal Trade Commission (FTC) to the largest Internet Service Providers (ISPs) in the United States, the FTC staff in late October issued a Report titled – A Look at What ISPs Know About You: Examining the Privacy Practices of Six Major Internet Service Providers. Among the agency staff’s general findings on ISP data collection and use practices, the most striking perhaps is the apparent degree of integration among ISPs and...

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The global economy continues to suffer from dislocations to supply chains, causing shortages and dramatic price spikes across products, industries, and geographies and hampering growth. Fears that these problems could ruin Christmas have fueled runs on turkeys and Christmas pudding in the United Kingdom and led President Biden to broker a plan to run around-the-clock port operations in Los Angeles. The consensus view seems to be that these issues are transitory and will work themselves out in the short to medium...

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Travelling in winter is an essential pleasure for all fans of road trips. The road runs fast, perhaps snow-lined, through picture-perfect landscapes seen through windows slightly misted up at the edges. Sometimes, in winter, it is as if the cold makes the asphalt more compact and suitable for our tyres, which of course must be of the winter variety suited for the weather, and particularly snow tyres in the mountains. Double the driving pleasure by heading off to destinations that...

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Creating the infrastructure to develop quick, new diagnostics was a major achievement of the COVID-19 pandemic. But we need to keep financing innovation to be ready for the next big one. The COVID-19 pandemic sent shockwaves through the medical diagnostics industry. Overnight, the demand exploded for diagnostics, such as tests, personal protective equipment and ventilators. Diagnostics makers tried to pivot operations to meet the overwhelming demand for COVID-19 tests and treatments, but many had difficulty marshalling the financing and manpower...

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Key insights Advertising and sponsorship acknowledgement can look very similar, but only advertising is subject to unrelated business income tax. Any message or material that promotes or markets any trade, business, service, facility, or product using the key factors defined by the IRS is considered advertising. A payment made by a trade or business where there is no arrangement or expectation of any return benefit is considered a sponsorship. An activity is subject to unrelated business income tax if...

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