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We explore the political reaction to the rules, current views on implementation timelines, some complexities we see in applying these rules practically, and what businesses can do now to get ready for the introduction of Pillar 2.

As most of the Base Erosion and Profit Shifting (BEPS) Action Plan is made up of best practice recommendations rather than ‘red line’ requirements, it was always going to be applied electively and in different ways from country to country.