On Tuesday 3 October, the OECD/G20 Inclusive Framework on BEPS completed negotiations on a multilateral agreement to facilitate the implementation of the global minimum tax liability rule.
This multilateral agreement will protect the right of developing countries to ensure that multinational enterprises pay a minimum level of tax on a wide range of cross-border intra-group payments, including for services. These countries will therefore be able to tax certain intra-group payments where...