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The BEPS 2.0 framework is reshaping global tax norms, compelling MNEs to realign transfer pricing strategies. Pillar One redefines profit allocation through Amount A and Amount B, while Pillar Two enforces a 15% global minimum tax via GloBE rules. Together, they curb base erosion and profit shifting, demanding stronger compliance, documentation, and governance. For businesses, the challenge lies in modeling exposures, adapting policies, and aligning with evolving OECD guidelines. SKMC Global supports enterprises in navigating Pillar One and Pillar Two by redesigning transfer pricing structure
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