Lauren Smyth, Senior Manager in Buzzacott's Business Tax team, has been featured in International Tax Review exploring HMRC's draft legislation implementing the OECD's pillar two side-by-side package for US multinationals with UK subsidiaries.

In the article, Lauren explains why the safe harbour is not automatic for these groups, and how the draft legislation gives HMRC control over its application as other jurisdictions come on board. She also covers the wider safe harbour changes, including the new permanent status of the simplified effective tax rate safe harbour and the extension of the transitional country-by-country reporting safe harbour.

For US-parented groups with subsidiaries in multiple countries, Lauren explains that the compliance burden isn't going anywhere fast. Where the safe harbour gets recognised in some jurisdictions well before others, the common frustrations about the lack of alignment across pillar two are likely to resurface.

Click here to read the full article on International Tax Review.