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The UTPR and the (disguised) discrimination under tax treaties - Kluwer International Tax Blog

Summary by Kluwer International Tax Blog
The authors are winners of the Mitchell B. Carroll Prize for the last two consecutive years, as awarded at the International Fiscal Association global congresses in 2023 and 2024 in Cancún (Mexico) and Cape Town (South Africa), respectively.*  The compatibility of the Undertaxed Profits Rule (UTPR) with tax treaties based on the OECD or the UN Model Tax Convention (MTC) is an overarching question for all multinational (MNE) groups in scope of Gl…
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Kluwer International Tax BlogKluwer International Tax Blog

The UTPR and the (disguised) discrimination under tax treaties - Kluwer International Tax Blog

The authors are winners of the Mitchell B. Carroll Prize for the last two consecutive years, as awarded at the International Fiscal Association global congresses in 2023 and 2024 in Cancún (Mexico) and Cape Town (South Africa), respectively.*  The compatibility of the Undertaxed Profits Rule (UTPR) with tax treaties based on the OECD or the UN Model Tax Convention (MTC) is an overarching question for all multinational (MNE) groups in scope of Gl…

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Kluwer International Tax Blog broke the news in on Friday, March 21, 2025.
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