The UTPR is Inconsistent with the Nexus Requirement of Tax Treaties
By Jefferson VanderWolk Partner, Squire Patton Boggs[1] The GloBE Model Rules were issued in final form in December 2021. No public consultation was undertaken regarding any draft Model Rules, as there was a need for speed in light of the tight timeline for implementation of Pillar Two’s 15% global minimum tax that had been agreed…