As this year nears its end, it is time for our annual tax bulletin. This bulletin not only focuses on the tax trends and developments we foresee for 2022, but also includes some tips and takeaways.

Focus on market trends

Hot topics addressed in this annual tax bulletin include the global agreement on Pillar One and Pillar Two, the European Commission's soon expected proposal on the abusive use of shell entities and its initiative on debt financing (Debt-Equity Bias Reduction Allowance (DEBRA)) as well as developments in tax transparency and transfer pricing. For MNEs that may be affected by Pillar One and/or Pillar Two, 2022 will be the year to assess the impact and potential actions needed to mitigate undesired effects. In transfer pricing, we see more and more multi-jurisdictional audits and multilateral agreement procedures. MNEs may want to prepare what to do in case they will face these. 

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