With the US administration having reached an agreement with the G7 to exempt US companies from the Global Minimum Tax Rules, what impact do you think this will have on the overall BEPS project and on Ireland as a location for US investment?
(This response could include consideration of the possible shape of the “side by side” solution under the OECD Inclusive Framework referenced in that agreement by which groups with US parents would be exempt from the Income Inclusion Rule and Undertaxed Profits Rule aspects of the Pillar Two framework in recognition of existing US tax rules setting minimum tax levels).