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Strong Dispute Resolution in Tax Deal Key to U.S., Official Says

March 22, 2022, 3:27 PM

The U.S. is pushing hard for broadly scoped binding dispute resolution for companies captured by the global tax deal’s reallocation rules, a Treasury official said.

“In our perspective, almost all transfer pricing and business profits disputes are meant to be in scope of mandatory binding resolution to avoid double taxation,” said Itai Grinberg, Treasury’s deputy assistant secretary for multilateral tax. He was speaking Tuesday at a Tax Executives Institute event.

“Amount A” of the 2021 global tax deal’s Pillar One reallocates a portion of the profits of the largest and most profitable multinationals to the jurisdictions where they make ...