Pillar Two Hybrid Arbitrage: stormy waters ahead?
Cross-border Tax Talks

Pillar Two Hybrid Arbitrage: stormy waters ahead?

2025-08-21

Doug McHoney is joined by Raza Janjua, a Director in PwC’s ITS practice in New York. They discuss the BEPS Action 2 origins and ATAD 2 implementation, how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules, and much more.

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