EACC & Member News

Loyens & Loeff: Pillar Two: Intragroup financing arrangements part 2 – New York office Snippet

Loyens & Loeff New York regularly posts ‘Snippets’ on a range of EU tax and legal topics. In a previous Snippet, we described hybrid financing arrangements (HFAs) under article 3.2.7 of the Pillar Two (P2) model rules. This Snippet describes the treatment of certain HFAs under the P2 guidance published by the OECD in December 2023 (the Guidance) for purposes of the transitional country-by-country reporting safe harbour (SH) rules.

Read more