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Few developments in the tax world have an impact on a truly global scale, but the so-called 'Pillar Two' rules – essentially a global minimum corporate tax – is one of them.

Pillar Two arose from the Organisation for Economic Co-operation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) project. Agreed in principle in 2021 by around 140 countries, Pillar Two is designed to end the 'race to the bottom' for corporate tax rates and remove the advantages of shifting profits to low-tax jurisdictions.

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